Ambulatory Specialty Model for Heart Failure: What ASE Members Need to Know

CMS Finalizes Mandatory Episode-Based Model for Heart Failure (HF)

Executive Summary
CMS has finalized a new mandatory, five-year Ambulatory Specialty Model (ASM) for chronic heart failure beginning in 2027, with the goal of expanding specialty participation in value-based care. Although financial accountability is limited to general cardiologists treating 20 Medicare Heart Failure (HF) beneficiaries in selected geographies, the model will meaningfully influence imaging utilization, documentation standards, and care pathways across cardiology practices. Echo and advanced imaging may receive increased scrutiny under episode-based cost measurement, heightening the need for strong clinical documentation, appropriate-use alignment, and consistent structured reporting to support risk adjustment and quality scoring. ASE will be closely engaged as implementation unfolds to ensure imaging remains appropriately valued, members receive timely education, and new performance frameworks reflect the central role of echocardiography in HF management.

Implementation Timeline

• November 2025: CMS finalizes ASM in the CY 2026 MPFS rule
• December 2025: Initial geographies and preliminary participant list released
• July 2026: Final participant list published
• January 1, 2027: ASM Year 1 begins
• December 31, 2031: Model concludes after 5-year performance period

Heart Failure Ambulatory Specialty Model Overview
CMS has established the Ambulatory Specialty Model (ASM), a mandatory, five-year value-based care program focused on managing chronic heart failure (HF) in the outpatient setting. The model aims to more actively involve specialists in cost and quality accountability while aligning incentives with MIPS Value Pathways and prior specialty-oriented pilots. Under ASM, CMS will attribute HF episodes to general cardiologists who have historically treated at least 20 Original Medicare HF beneficiaries, are enrolled through PECOS under general cardiology taxonomy codes, and practice in selected geographies that CMS will announce in late 2025. Interventional cardiologists, electrophysiologists, and advanced HF/transplant specialists are excluded. CMS will issue a preliminary participant list in December 2025 and finalize it in July 2026. Performance will be evaluated annually using a structure similar to MIPS-risk-adjusted cost, HF-specific outpatient quality measures, improvement activities, and interoperability requirements-with clinicians facing upward or downward payment adjustments based on their results.

Although echocardiographers and other imagers are not directly attributed participants, the model will substantially influence imaging practice patterns within chronic HF care. General cardiologists facing spending accountability may adopt more conservative imaging utilization patterns, particularly around repeat transthoracic echocardiography, stress imaging, and advanced modalities such as CMR and CT. This environment will increase the importance of clear clinical justification and documentation aligned with appropriate-use criteria. Imaging data-including ejection fraction, chamber size and function, valvular assessment, pulmonary pressures, and strain-will play a greater role in risk adjustment, quality scoring, and phenotype classification, prompting demand for standardized measurement practices and structured reporting templates. The ASM’s emphasis on chronic disease management will also expand opportunities for imagers to support HF clinical pathways, multidisciplinary case reviews, and practice-level performance reporting. Organizations may respond by establishing HF care bundles, preferred imaging intervals, and internal decision-support protocols that integrate imaging with medical therapy optimization and population health objectives.

ASE will be closely following how the ASM rolls out and will advocate to make sure echocardiography’s role in heart failure care is clearly reflected in the model’s quality measures, documentation expectations, and value metrics. We will also develop practical, member-focused tools—such as coding guidance, documentation tips, quality measure support, and educational resources—to help your practice understand the new requirements and ensure that imaging remains appropriately recognized and integrated within team-based HF management.

Additional Resources

• ASE Webpage on CY 2026 Physician Fee Schedule Final Rule
• CY2026 Medicare Physician Fee Schedule Final Rule
• CMS Fact Sheet on the Physician Fee Schedule
• CMS Press Release on the Physician Fee Schedule