American Society of Interventional Pain Physicians

ASIPP Membership Update on ASM and Gold Standard Science

October 21, 2026

Dear ASIPP Members,

ASIPP continues to work actively to address serious concerns about the Centers for Medicare & Medicaid Services’ Ambulatory Specialty Model (ASM) and its implications for interventional pain physicians and the patients we serve.

We want our members to know that these efforts are ongoing through direct communication with CMS leadership, congressional outreach, and a detailed examination of the model’s scientific foundations.

Our advocacy efforts

ASIPP has been in contact with congressional committee leadership and offices responsible for oversight, government regulation, and energy and commerce. We have mailed letters to CMS Administrator Dr. Mehmet Oz and relevant committee chairs outlining our concerns and requesting action.

Read ASIPP’s recent correspondence:

• Letter to CMS Administrator Dr. Mehmet Oz

• Letter to House Oversight Committee Chairman James Comer

• Letter to House Energy and Commerce Committee Chairman Brett Guthrie

Congressional offices have continued to inquire about ASM. These efforts build on earlier letters from multiple members of Congress requesting that CMS drop the model. Scheduled meetings with Oversight Committee leadership provide another opportunity to present our concerns and seek meaningful intervention. We remain hopeful that these discussions will produce results, although no resolution has yet been secured.

Why Gold Standard Science matters

Our recent review of Gold Standard Science and its relationship to ASM strengthens the scientific basis for asking CMS to explain and substantiate its approach.

Executive Order 14303, “Restoring Gold Standard Science,” establishes principles that include reproducibility, transparency, clear communication of uncertainty, unbiased peer review, and scrutiny of scientific assumptions. These principles are directly relevant to the data, models, and analyses used to inform federal policy.

ASIPP’s position is straightforward: CMS should demonstrate that the scientific foundations of ASM meet the administration’s own stated standards before physicians face financial consequences under the model.

The relationship among clinical evidence, performance measurement, and payment is critical. Evidence that a treatment benefits appropriately selected patients does not automatically validate a payment model. Likewise, a reduction in spending or procedure use does not, by itself, establish better patient care.

Our scientific review identifies several questions that deserve clear, publicly accessible answers:

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Clinical validity: Can the model distinguish unnecessary services from appropriate treatment for patients with different pain conditions and levels of complexity?

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Fair attribution: Are physicians being assessed for care and spending they can reasonably influence?

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Adequate risk adjustment: Do comparisons sufficiently account for differences in patient severity, disability, prior treatment, and other relevant circumstances?

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Reliable assessment: Are physician performance estimates sufficiently stable to justify financial consequences, particularly when episode numbers are limited?

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Patient protection: Will evaluation adequately examine function, access to care, complications, and possible avoidance of complex patients?

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Transparency and correction: Are the supporting methods, validation findings, uncertainties, and criteria for revising the model available for independent scrutiny?

CMS describes its episode-based cost measures as validated. ASIPP’s concern is whether the available validation sufficiently establishes their fitness for the specific patients, practices, and financial decisions involved in ASM.

These are substantive scientific questions. A model’s stated goals do not establish that its methods will achieve those goals, and anticipated savings do not establish improved clinical outcomes.

Where matters stand

ASM is currently scheduled to begin its first performance year on January 1, 2027. We are awaiting the forthcoming 2027 Medicare Physician Fee Schedule final rule and will assess its implications for ASM when released.

ASIPP continues to press for withdrawal of ASM and to emphasize the need for transparent scientific justification and meaningful patient safeguards. Congressional inquiries and scheduled meetings are important opportunities, but they should not be interpreted as a commitment by CMS to withdraw or change the model.

Your membership supports this work

ASIPP membership sustains the scientific review, regulatory analysis, and congressional engagement needed to represent our specialty and protect patient access. Members’ documented experiences with administrative burden, complex referrals, and barriers to appropriate care can also help strengthen this effort.

We will continue to keep you informed as discussions progress and additional decisions become available. Our commitment remains to fair evaluation of physicians, scientifically defensible policy, and access to appropriate interventional pain care.

Thank you for your continued membership and support.

Laxmaiah Manchikanti, MD

Chairman of the Board and Chief Executive Officer, ASIPP and SIPMS

Director, Pain Management Centers of America

Ambulatory Surgery Center and Pain Care Surgery Center

Clinical Professor

Anesthesiology and Perioperative Medicine

University of Louisville, Kentucky

Professor of Anesthesiology-Research

Department of Anesthesiology, School of Medicine

LSU Health Sciences Center

Shreveport, LA