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Updates for Members and Partners
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HELP INFORM NAACOS ADVOCACY ON ADVANCED APM INCENTIVES AND THRESHOLDS
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NAACOS is seeking input from ACOs to help determine the appropriate level of the qualifying participant (QP) thresholds. Beginning in Performance Year (PY) 2025, ACOs must meet higher QP thresholds — 75 percent of Medicare payments or 50 percent of Medicare patients — to qualify as advanced alternative payment model (APM) participants (i.e., QPs). We are calling on Congress to reinstate the advanced APM incentives and lower QP thresholds. Please complete this brief survey to inform us of the appropriate level for QP thresholds.
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FEDERAL GOVERNMENT SHUTDOWN: WHAT HAPPENS NEXT
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On Tuesday, Congress failed to pass legislation to extend federal funding due to a partisan impasse over extending health care tax credits and reversing Medicaid cuts enacted earlier this year. As a result, a partial government shutdown began on October 1, 2025. This resource from our consultants at Hart Health Strategies provides an overview of the shutdown status and impact on federal agencies and programs. Of note:
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- CMS does not anticipate delays in payments to ACOs. Advance Investment Payment (AIP) are scheduled for early October, and shared savings payments for MSSP are scheduled for mid-October. Similarly, CMS does not anticipate delays in demand and remittance instructions for ACOs owing shared losses.
- Telehealth policies will generally revert to pre-pandemic requirements; however, certain ACOs can utilize telehealth waivers. See the CMS guidance on telehealth and telehealth fact sheets for MSSP ACOs and REACH ACOs.
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The NAACOS government affairs team is closely following the government shutdown and will provide updates as the situation continues to evolve. If you need assistance, or experience disruptions at CMS due to the shutdown, please contact us at [email protected].
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WHITE HOUSE ANNOUNCES ‘MOST-FAVORED-NATION’ PRICING WITH PFIZER
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As part of the administration’s efforts to reduce drug costs in the United States, the Trump Administration announced a deal with Pfizer to price drugs at levels comparable to other nations. The deal will provide state Medicaid programs access to most-favored-nation drug prices, increase foreign revenues, and offer discounts to U.S. patients buying medication directly from Pfizer. The deal follows the administration’s deadline for pharmaceutical companies to lower prices.
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REVISED MSSP ACO PY 2024 FINANCIAL AND QUALITY RESULTS RELEASED
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On September 29, 2025, ACOs received their Notice of Revised PY 2024 Unembargoed Financial Reconciliation Settlement Reports in the Data Hub in ACO-MS. NAACOS is thrilled to see that for PY 2024 CMS observed “the highest share of ACOs receiving performance payments and the highest amount of savings for ACOs and Medicare since the inception of the Shared Savings Program.” Earlier this month, CMS alerted MSSP ACO participants of errors in the calculation of PY 2024 financial reconciliation. For more information, see the MSSP ACO Updated PY 2024 Financial and Quality Results CMS Fact Sheet.
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PY 2024 ACO REACH FINANCIAL SETTLEMENT REPORTS RELEASED
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In the final weeks of September, ACOs received their PY 2024 ACO REACH Financial Settlement Reports. NAACOS is elevating feedback to CMS raised by members during a recent ACO REACH Roundtable concerning elements within the report, such as variances observed between the preliminary and final settlement, changes to quality performance calculations, and gaps in the implementation guidance. Updates from NAACOS will be shared soon. As a reminder, CMS is holding a webinar in review of the financial settlement reports on October 9 at 2:00 pm. Register to attend the event.
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UPDATED INFORMATION ON PI AND QUALITY IN ACO SPOTLIGHT
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This week, CMS published updated information for MSSP ACOs in the ACO Spotlight newsletter on Promoting Interoperability (PI) requirements for ACOs and reporting of the breast cancer screening (BCS) measure for PY 2025. Specifically:
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- CMS announced that MSSP participants who attain QP or partial QP status and are therefore not Merit-based Incentive Payment System (MIPS) eligible will now be able to apply for the MIPS Promoting Interoperability Performance Category Hardship Exception. Hardship exceptions are available when: your electronic health record (EHR) is decertified, you have insufficient internet connectivity, you face extreme and uncontrollable circumstances, or you lack control over the availability of Certified EHR Technology (CEHRT). The deadline to apply for a hardship exception PY 2025 is 8:00 pm ET on December 31, 2025.
- In response to concerns with the misaligned age years for the electronic clinical quality measures (eCQMs) and MIPS CQM collection types for the BCS measure for PY 2025, CMS suggests that ACOs should consider reporting as a Medicare CQM, noting that only three percent of beneficiaries estimated to be eligible for the measure fall within the 40-49 age range, in order to meet data completeness.
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Unfortunately, this guidance does not address all the questions and concerns that NAACOS has relayed to CMS on these topics. In particular, NAACOS continues to urge CMS to hold ACOs harmless if they cannot report the BCS measure for PY 2025 due to vendors failing to support the measure and to educate vendors on which measures are required for MSSP. If your ACO is experiencing challenges with the BCS measure or PI reporting, contact Alyssa Neumann for more information.
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DON’T MISS FALL CONFERENCE NEXT WEEK! REGISTER TODAY OR ONSITE
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Connect and learn at the Marriott Marquis Washington, D.C., on October 8-10 at the Fall 2025 Conference! The agenda features expert-led sessions providing real world value-based care strategies, as well as networking opportunities for participants, speakers, and vendors to share ideas, explore partnerships, or gain insider insights. Agenda highlights include:
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- Thursday Plenary features Dr. Pippa Shulman of American Academy of Home Care Medicine and DispatchHealth, a pioneer in delivering acute care in the home
- Networking lunch on Thursday to connect with fellow attendees, speakers, and industry leaders in a relaxed and engaging setting
- A Health Care Investor Roundtable on Friday morning moderated by Sean Cavanaugh, Aledade, bringing together leading voices in healthcare investment
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Registration is open and will remain open through the conference.
Can’t attend in person? Register for the live webcast.
As always, the entire conference will be recorded. All participants, both in-person and virtual, will be able to view any sessions they missed live for six months following the conference.
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JOIN US IN PHOENIX IN-PERSON FOR SOUTHEAST REGIONAL MEETING
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The Southwest regional meeting will be held on November 6, 2025, from 8:00 a.m. to 3:00 p.m. in Phoenix, AZ. Registration is now open. If you are interested in speaking or shaping this meeting’s agenda, email [email protected].
Regional events are open to NAACOS members, non-member ACOs, and value-based care providers. Virtual events are complimentary. In-person events are $250 per registrant, and each NAACOS ACO and value-based care provider member receives one complimentary registration per calendar year, with unlimited additional registrations to be purchased at the prevailing rate. Contact [email protected] to utilize your complimentary registration or with any questions. These events are not open to non-sponsoring business partners.
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VIRTUAL BOOT CAMP 201 ANNOUNCED FOR JANUARY 2026
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Mark your calendars, Data & Analytics Boot Camp 201 will be held January 21-23, 2026, and Clinical & Operations Boot Camp 201 will be held January 28-30, 2026. Registration will open soon! These sessions will be presented at an intermediate-to-advanced level and will provide an understanding of Medicare accountable care and population health to maintain administration and operational functions of a successful ACO. Boot Camp 201 is only open to employees at ACOs and VBC provider groups and not vendors. If you are interested in speaking or shaping these meeting agendas, email [email protected].
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- A recent New England Journal of Medicine Catalyst article found that Medicare Advantage (MA) beneficiaries Advantage (MA) beneficiaries whose primary care providers (PCPs) participate in value-based care models had greater primary care intensity than MA beneficiaries receiving primary care from fee-for-service primary care providers.
- The Center for Health Care Strategies (CHCS) recently updated its evidence roundup on Medicaid ACO programs and related resources.
- A recent article in Medical Economics emphasizes that VBC success depends on deeper collaboration between payers and providers. To increase successful VBC adoption, stakeholders must build from shared vision and language, mutual education and trust, data exchange, and predictive analytics.
- The Healthcare M&A Mid-Year Insight report from Modern Healthcare revealed a mixed landscape for healthcare mergers and acquisitions, where overall deal volume slowed due to economic challenges and regulatory ambiguity. Organizations are adopting more selective and strategic approaches to focus on longer term transformation rather than short-term deals.
- A Health Affairs study revealed that the number of family caregivers supporting older adults in the United States rose from 18 million in 2011 to 24 million 2022. The article highlights the growing complexity of caregiving tasks and calls for better integration of caregivers into care teams, along with expanded training and financial support.
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