Financial Benchmarking

ACO performance is measured using a multi-step process that evaluates an ACO’s effectiveness in lowering expenditures for a group of assigned beneficiaries against a financial benchmark reflective to historical costs. Benchmarks are initially established for new ACOs, updated during agreement periods and reset or rebased when ACOs enter subsequent agreement periods. Benchmarking is fundamental to ACOs’ success and a source of NAACOS advocacy in the past. CMS has updated its benchmarking methodology multiple times, most notably by introducing regional expenditure data over the course of ACO agreement periods. 


  • MSSP benchmarking methodology is outlined in this CMS resource
  • CMS regulations governing benchmarking methodology are here and here

  • CMS webinar slides on ACO REACH’s financial methodology

News and Advocacy 

  • May 2022 NAACOS webinar: “A Look into MSSP Benchmark Report Trends and Implications” 
  • NAACOS and 12 others write Congress in support of the Accountable Care In Rural America Act (H.R. 3746)
  • NAACOS in-depth analysis of the final Pathways to Success rule, which included several changes to benchmarking methodology
  • NAACOS resource on the Effect of Medicare Classifications of ESRD Beneficiaries on ACO Expenditures>

  • NAACOS Summary of Final 2016 MSSP Benchmarking Rule 

    • NAACOS and Other Prominent Organizations Submit Comments to CMS on Regional Benchmarking NPRM 

  • NAACOS comments Health Care Payment Learning & Action Network Financial Benchmarking White Paper
To read more about developments related to Financial Benchmarks and other key policy issues effecting ACOs, please visit our newsletter page. 

 indicates members only resource.