As we approach the Medicare Shared Savings Program (MSSP) Phase 1 application period for Performance Year (PY) 2026, now is the time to take stock of how changes in the Medicare policy environment affect current and prospective Accountable Care Organizations (ACO). For a more detailed review of application timeline and strategic considerations, refer to our previous article. Here are a few of the most impactful expectations and updates – and what they could mean for ACOs.

1. Dr. Oz Has Championed Value-Based Care as CMMI Has Terminated Certain Models
Dr. Oz has emerged as a public and outspoken advocate for value based care, emphasizing the need to move away from fee-for-service models and toward systems that prioritize better outcomes and patient satisfaction. All this while the Center for Medicare and Medicaid Innovation (CMMI) has terminated certain total cost of care models, including Making Care Primary and Primary Care First. Overall, there remains a strong push towards value based care and increased financial accountability within the Medicare program and support for both MSSP ACOs and the next iteration of ACO REACH.

2. Anticipated Acceleration of Two-Sided Risk in CMS Models
While not yet formally implemented, there is some anticipation that CMS will once again push for a faster transition to two-sided risk in its value-based care programs – mirroring the approach of the 2018 “Pathways to Success” initiative under the Trump administration.

• Reduced Timeframe for Upside-Only Models: New ACOs can remain in upside-only models for a maximum of two years, opposed to six years, to accelerate their transition to performance-based risk arrangements.
• Enhanced Shared Savings Rates: ACOs that take on higher levels of risk are eligible for increased shared savings rates, providing greater financial incentives for improved care delivery.
• Expanded Telehealth Services: The program allows for the provision of telehealth services to patients at their place of residence, increasing access to care for those facing barriers and supporting patient engagement.
• Beneficiary Incentives: ACOs are permitted to offer incentive payments to beneficiaries who engage in health-promoting behaviors, such as receiving primary care services and necessary follow-up care.

Implications for ACOs: These policy shifts – both expected and confirmed – actively encourage ACOs to take on more responsibility for quality and total cost of care.

1. Increased Accountability: ACOs will need to enhance care coordination and management to meet quality and cost benchmarks, requiring investments in data analytics and care management infrastructure.
2. Financial Risk Management: With the move towards two-sided risk models, ACOs must develop risk management strategies to mitigate potential financial losses while striving for shared savings.
3. Emphasis on Patient Engagement: Successful ACOs will prioritize patient-centered care approaches, leveraging beneficiary incentives and telehealth options to improve patient outcomes and satisfaction.
4. Adaptation to Regulatory Changes: ACOs must stay informed, adapting to ongoing regulatory changes and ensuring compliance with new program requirements.

As the industry continues to evolve, the need for reliable, strategic partnerships has never been greater. Let’s discuss how CHS can help your organization build a sustainable, provider-driven value-based care strategy—one that puts you in control. We would love to hear from you, potentially become your MSSP partner, and accelerate your broader value-based care journey. Please do not hesitate to reach out at info@copehealthsolutions.com or 213-259-0245.