The Texas Medical Association has asked CMS to delay its mandatory Ambulatory Specialty Model, arguing physicians need final participation details and time to prepare before facing significant Medicare payment risk.
TMA made the request in a Sept. 14 comment letter on the proposed 2027 Medicare physician fee schedule. TMA President Bradford Holland, MD, wrote that the association still opposes mandatory participation. Dr. Holland urged CMS, at minimum, to give physicians a period of actionable performance feedback “before physicians are subject to downside risk.”
CMS has not changed course. The agency published its final participant list, which includes 960 Texas physicians, or 17% of the more than 5,500 participants nationwide. The five-year model begins Jan. 1, 2027.
The stakes TMA flagged are financial. The association said payments in 2029, based on 2027 performance, can rise or fall by up to 9%, and CMS plans to widen that range to 12% before the model ends. Because CMS scores each physician against peers in the same cohort and specialty, the threshold for avoiding a cut won’t be known in advance.
TMA backed several proposed refinements, including a five-point rural practice adjustment, voluntary patient-reported outcome data and a participant exception process. It also urged CMS to add an adjustment for physicians who treat large numbers of low-income and socially complex patients. The association asked CMS to let physicians correct data errors before scores become final.
Small practices are heavily represented: 41% of the 346 Texas cardiologists and 56% of the 614 Texas low back pain physicians in the model work in groups of 15 or fewer physicians.
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