Statement
Date: July 14, 2025

NAACOS Responds to Proposed 2026 Medicare Physician Fee Schedule

Statement from Emily Brower, president and chief executive officer, the National Association of ACOs

WASHINGTON (July 14, 2025) – The National Association of ACOs (NAACOS) is encouraged by Centers for Medicare and Medicaid Services attention to wasteful and abusive billing practices in the proposed 2026 Medicare Physician Fee Schedule and remains ready to support development of smart regulations and policies.

We applaud CMS for proposing new payment policies to pay for skin substitutes. Unfortunately, many Accountable Care Organizations (ACOs) continue to be held financially accountable for this unnecessary spending. In our shared fight against bad actors, more must be done to hold ACOs harmless for significant, anomalous, and highly suspect billing. Our members look to partner with CMS to identify and report suspected waste, fraud, and abuse and improve policies moving forward.

We also look forward to working with CMS to address critical issues that threaten the long-term sustainability of accountable care and value-based payment models. This includes the benchmark “ratchet” which penalizes ACOs for past strong performance and the quality improvement approach which forces ACOs to make significant investment in interim solutions ahead of digital quality measurement. The proposed 2026 Medicare Physician Fee Schedule stops short of addressing these issues.

Accountable Care Organizations have demonstrated extraordinary impact over the past 15 years by routinely improving health outcomes and reducing costs. NAACOS aims to work alongside CMS to achieve our shared goal of allowing more seniors to benefit from accountable care that improves patient outcomes and reduces spending.