• • •NAACOS Advocacy |
REGISTER TODAY: NAACOS FALL ADVOCACY SUMMIT & HILL DAYJoin fellow NAACOS members for a unique opportunity to engage with lawmakers and their staff in Washington, D.C. during our second annual Fall Advocacy Summit and Hill Day. Register before June 30, 2025.
Courtyard Marriott Convention Center
901 L Street NW, Washington, DC 20001
Wednesday, September 10 – Thursday, September 11, 2025 |
NAACOS DRAFT IPPS COMMENTS AVAILABLE
A draft version of our comments in response to the 2026 Inpatient Prospective Payment Systems (IPPS) proposed rule is available now. NAACOS comments focus on the proposed changes for the Transforming Episode Accountability Model (TEAM) and a request for information (RFI) on transitioning to digital quality measurement (dQM). Share any additional feedback with [email protected]. We encourage you to use our comments in your own submission. Comments are due by Tuesday, June 10, 2025, and can be submitted via regulations.gov.
| UPDATED NAACOS RESOURCES AVAILABLE
Anomalous billing for skin substitutes: The NAACOS overview reviews the issue and details our policy priorities for mitigation. The provider outreach template is a resource for educating your participating practices on the issue. Accountable Care Prospective Trend (ACPT) in MSSP. - The Institute for Accountable Care published an article in Health Affairs Forefront on challenges and opportunities with the ACPT.
- Thanks to members who signed on to the letter asking CMS to reweight the ACPT to 0%. CMS has sought additional input on our recommendations. See the updated overview for NAACOS policy positions.
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PROVIDE FEEDBACK TO CMS ON THE HEALTH TECHNOLOGY ECOSYSTEM
The Centers for Medicare & Medicaid Services (CMS) and Assistant Secretary for Technology Policy /Office of the National Coordinator for Health Information Technology (ASTP/ONC) released a request for information seeking input on digital health products for Medicare beneficiaries as well as the state of data interoperability and broader health technology infrastructure. Notably, the RFI seeks input on use cases and workflows that involve value-based care organizations. NAACOS will be preparing comments in response to this RFI. If you’re interested in informing NAACOS comments, please register for our Discovery Call on Tuesday, June 3, from 2:30-3:30pm ET.
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Congressional Updates |
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VALUE-BASED CARE STAKEHOLDERS SEND LETTER TO CONGRESS ON APM INCENTIVES
NAACOS and our partners in the Alliance for Value-Based Patient Care led a coalition letter with more than 500 ACOs, hospitals, and physician practices calling on Congress to extend Medicare’s advanced APM incentives and adjust qualifying thresholds. A special thank you to all the ACOs, practices, and partners that joined us in calling on Congress to extend these critical incentives. |
ADVANCED APM INCENTIVES: CONGRESSIONAL PROPOSAL THREATENS INCENTIVES
House Republicans passed a budget reconciliation plan to advance President Trump’s agenda which includes extensions of tax policy, more than $600 billion in reductions to Medicaid, and changes to Medicare. The bill now goes to the Senate where it will be debated over the coming weeks.
What This Means for Accountable Care:
The Medicare Access and CHIP Reauthorization Act (MACRA) encouraged adoption and continued participation in advanced APMs by rewarding physicians and other health care providers with higher payment updates. In the initial years, clinicians in risk-bearing (advanced APMs) received an incentive payment for participation in advanced APMs. Beginning in 2026, clinicians in advanced APMs would receive a 0.75 percent update while clinicians not in risk-based models received a 0.25 percent update.
The proposal in the reconciliation bill would eliminate this differential conversion factor update and provide a flat inflationary update to all clinicians. The update in 2026 would be 75 percent of the Medicare Economic Index (MEI) and 10 percent of MEI for 2027 and beyond. Payments to clinicians who are not in advanced APMs would see slightly higher reimbursement rates over the next 10 years. Payments to clinicians in advanced APMs would be higher than current law in the initial years (2026–2028), but lower than current law for 2029 and beyond.
Combined with the upcoming expiration of advanced APM bonuses, these changes eliminate key financial incentives to deliver high-value, patient-centered care. While lawmakers have signaled that they intend to address advanced APM incentives outside the reconciliation process, we must engage with lawmakers to ensure they follow through. A NAACOS statement and talking points document are available.
Here’s How You Can Help:
Contact your Representatives, share the stakeholder letter and ask them to preserve value-based care by maintaining incentives for advanced APMs. NAACOS is reaching out to Republican lawmakers on the Senate Finance Committee asking them to include financial incentives for clinicians in advanced APMs in the reconciliation bill. If your ACO has participants in Idaho, Iowa, Kansas, Louisiana, Montana, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, Wisconsin, or Wyoming, please contact Robert Daley to coordinate outreach. |
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• • •Administration Updates |
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ACO REACH CHANGES ANNOUNCED
Last week, CMS announced a set of changes to the ACO REACH Model for performance year (PY) 2026, intended to increase model savings to CMS following initial evaluations that show the model has thus far resulted in net losses to CMS. These changes include:
Modifying risk score growth constraints by removing the exemption from risk score caps for ACOs with beneficiary populations at least 3 times the reference year population, applying an additional 3 percent cap on risk score growth for Standard ACOs, and applying an increased coding intensity factor of 2 percent and an asymmetrical risk score growth cap of 8 percent for High Needs ACOs, Reducing the regional component of the benchmark by shifting the historical/regional blend to 60/40 percent for Standard ACOs and to 55/45 percent for New Entrant and High Needs ACOs, Narrowing the first risk corridor from 25 percent to 10 percent for the Global Track, Increasing the quality withhold from 2 percent to 5 percent and proportionally increasing the High Performers Pool (HPP) Bonus, Updating the risk adjustment model by increasing the weight of HCC v28 to 100 percent, and Adjusting PY2024 expenditures for significant, anomalous, and highly suspect (SAHS) billing by removing two HCPCS codes for catheter supplies and ostomy bags (A4353 and A5057) from 2024 expenditures and re-calculating the retrospective trend adjustment and stop loss and excluding these codes from historical benchmark years for PY2024.
NAACOS plans to respond to CMS regarding these changes. Contact [email protected] to share feedback on how these changes would impact your ACO. |
KIDNEY CARE CHOICES (KCC) MODEL CHANGES
CMS recently announced changes to the KCC Model for PY2026 in response to recent evaluations showing the model has resulted in net losses to CMS. Similar to the changes announced for ACO REACH, the KCC changes are intended to improve the model’s financial sustainability. Model changes include:
Expansion of the Core-Based Statistical Area (CBSA) rules to other U.S. territories, Addition of a 1 percent discount for the chronic kidney disease (CKD) benchmarks, Addition of the 1 percent discount for participants in the Professional risk track (currently only for Global track), Reduction of the Chronic Kidney Disease Quarterly Capitation Payment (CKD QCP) by half the amount of the enhanced portion, Elimination of the Kidney Transplant Bonus (KTB), Early termination of the Kidney Care First (KCF) option after December 31, 2025, and Extension of the Comprehensive Kidney Care Contracting (CKCC) option through December 31, 2027.
More information can be found on the KCC Model webpage. Contact [email protected] to share feedback on how these changes would impact your kidney contracting entity. |
2026 MSSP APPLICATIONS AND CHANGE REQUESTS NOW OPEN
Phase 1 of the MSSP application and change request cycle is open now through Thursday, June 12 at 12:00pm ET. Entities interested in applying as new, renewing, or re-entering ACOs seeking to participate in MSSP with an agreement start date of January 1, 2026 must submit an application during this window. This is also the timeline for currently participating ACOs to submit change requests for PY2026.
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Education Opportunities |
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101 BOOT CAMPS ONLY A FEW WEEKS AWAY!
Ready to learn the how and why of ACO basics? Don’t miss our live virtual events: Data and Analytics Boot Camp 101, June 17-18, and Clinical Operations Boot Camp 101, June 24- 25. Learn from our experienced members how they use the tools provided under MSSP and ACO REACH programs to design, implement and drive successful population health programs in their organizations.
The Data and Analytics Boot Camp 101, will feature Gabriel Orthous, Health Choice Network; Eileen Ciesco, Ed Higgins, Jamie Jarmul, and Stephen Steward, UNC Health Alliance; Jordan Catlin and Lacy Thomas, Ardent Health; Michael Barbati, Advocate Health; Ron Russell, Sound Physician; Mia Flood, Village MD; and James Barr, Atlantic Health System. The Clinical Operations Boot Camp 101 will feature discussions led by Kathy Harris, Commonwealth Health; Joyce Colton, Ascension; Meredith Maynard and Rebecca Goodman, Ardent Health; Karri Brown and Shital Tanna, Advocate Health; Alison Glendenning, Ochsner Health Network; and Leslie Cribbs Nowack, Trinity Health.
Check out both events on our Boot Camp webpage for more information on the agenda and to register. |
REGISTER EARLY FOR FALL CONFERENCE AND SAVE!
Join us at the Marriott Marquis Washington D.C. October 8–10 for the Fall 2025 Conference! The agenda will feature the insights of CMS officials, leading healthcare experts and policy insiders, and also provides networking opportunities for participants, speakers, and vendors. Register to attend before August 15 for the in-person conference and receive a discount of $300 per person. Can’t attend in person? Register for our live webcast before August 15 and receive a discount of $100 per person.
The exhibit/sponsor program applications for the fall conference are now being accepted. Reserve your space today! Please note, all sponsorships and exhibit space are on a first come first serve basis and space is assigned in the order we receive applications.
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REGISTRATION FOR IN-PERSON MIDWEST REGIONAL MEETING NOW OPEN
Registration is now open for the August 15 Midwest Regional Meeting which will be held in Indianapolis, IN. As promised, NAACOS is expanding our educational events to bring them closer to home. This is a great opportunity for members to discuss both local and national program participation and develop additional network connections in the value-based care space. Our regional events are open to NAACOS ACO Members, non-members, and value-based care providers. These meetings are meant to provide a space for discussion inclusive of the full care continuum, including ACOs, clinically integrated networks, provider practices, hospitals, home health, SNFs, hospice providers, community-based organizations (CBOs), and more. The goal is for participants to develop a deeper understanding of the successes and challenges that still exist in population health care and contracting to meet the needs of health care organizations and, most importantly, patient populations. Session topics and speakers can be found on our Midwest Regional Meeting Registration page. This event will be held at the Ruth Lilly Health Education Center, Indianapolis, IN, from 10 am to 5:30 pm ET. Seating will be limited to around 100 attendees, so reserve your seat today! Information on additional in-person and virtual regional meetings can be found on our Regional Meetings page.
| PARTNERS: REGISTER FOR SECOND QUARTER PARTNER CALL!
NAACOS Partners! Join us on Thursday, June 12 at 12:30 pm ET for an engaging and informative call exclusively for Partner Circle, Business Partners, and Alliance Partners. NAACOS staff will provide an update on our latest initiatives and strategic priorities, as well as review upcoming opportunities to showcase your brand at conferences, regional meetings, and more. Don’t miss this chance to fully utilize the benefits of your NAACOS partnership. This meeting is only open to Partners. |
REGISTER FOR UPCOMING SPONSORED WEBINAR
As ACOs take on more risk and expand across diverse payer arrangements, a unified, data-driven strategy is critical for long-term success. Join this expert-led session to learn how leading ACOs are navigating multi-payer complexity to drive performance, improve outcomes, and unlock new revenue opportunities. Sponsored by NAACOS business partner, Innovaccer, this webinar entitled The Multi-Payer ACO Playbook for Sustainable Revenue Growth will be held Tuesday, June 10 from 12:30 PM – 1:30 PM ET and is free for all members. Register today!
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• • •What We’re Watching:
News About ACOs and Health Care
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- A bipartisan group of lawmakers reintroduced legislation to streamline the prior authorization process in Medicare Advantage.
- Innovaccer and NAACOS partnered together on The State and Science of Value-Based Care 2025, examining the evolving landscape of healthcare payment models and value-based care programs, based on a survey of healthcare professionals.
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