

The CMS PFS Final Rule is out . . . early? If you’re wondering how, in the midst of the Shutdown, a 2,375-page Rule could be released, the answer is simple: most of the proposals from this summer were finalized as is.
There are always exceptions, but the big takeaway is that this Rule solidifies CMS’s proposals to control the Total Cost of Care. Through a variety of finalized proposals, we’ve identified five themes that illustrate how they intend to accomplish this, and what it means for you.
1. Bit by Bit, Everyone Will be Shunted into Two-Sided Risk
The key tenet in CMS’s push to save money through accountable care relationships is that providers must be at financial risk. A program that will pay providers a bonus but not recoup high costs will not reduce CMS expenditures. Through a new and mandatory program, the Ambulatory Specialty Model (ASM), and a change to the Medicare Shared Savings (MSSP) ACO model, the theme of two-sided risk will have an extremely broad impact across organizations and providers.
The Ambulatory Surgical Model (ASM) was finalized as a mandatory model for providers treating patients with heart failure or low back pain. The program is set to begin in 2027 and run for seven years (including post-reporting payment years).