October 27, 2026

RE: Ambulatory Specialty Model (ASM)

Dear Deputy Administrator Sutton:

The undersigned organizations appreciate the webinars, office hours, and recently proposed technical refinements to the mandatory Ambulatory Specialty Model (ASM) by the Center for Medicare and Medicaid Innovation (CMMI) that address stakeholder feedback. Specifically, we appreciate the proposal to allow the exclusion of certain non-relevant cardiac subspecialties from the model and several revisions to Promoting Interoperability requirements to reduce reporting burden.

However, significant operational and technical issues remain that should be addressed to enable participants to focus on delivering high-quality care to Medicare beneficiaries. Delays in participant identification, online portal access, operational guidance, and technical support have materially constrained participants’ ability to prepare. Given the model’s significant financial risk and its imminent January 1, 2027 start date, if these issues are not resolved, participants’ focus and resources will be diverted to resolving avoidable operational and technical challenges and could undermine both participant performance and the validity of the model’s early results.

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