Pathways to Success


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The Centers for Medicare & Medicaid Services (CMS) finalized on December 21 an overhaul to the Medicare Shared Savings Program (MSSP), Medicare’s largest value-based payment program, which it calls Pathways to Success. Many of the concessions CMS made in the final rule were the result of NAACOS advocacy, such as an additional year in shared savings-only models for some new ACOs, higher shared savings rates, and in increase in the threshold in distinguishing high and low revenue ACOs. The final rule contains several other positive changes including increased flexibility in choice of assignment methodology, longer, five-year agreement periods, and more waivers like that for telehealth and skill nursing facility stays. While an improvement over the proposed rule, the final rule still includes several challenges like less time in shared savings-only or low risk models than the program offers currently and distinguishing between high and low revenue ACOs.

The rule can be accessed here along with a related CMS factsheet and press releaseClick the image to the right for our in-depth analysis of the rule, detailing everything ACOs need to know about the final changes. Additional information on the MSSP can be found on this NAACOS page. NAACOS continues to advocate for polices that ensure the long-term success of Medicare ACO programs and educate members on the rule and what it means to them. 

NAACOS Member Resources 

  • NAACOS ACO Comparison Chart updated for 2019 to reflect the new Pathways structure and old MSSP structure 

  • NAACOS chart comparing Direct Contracting and other high-risk ACOS

  • NAACOS review assesses the impact of high-low revenue designations

  • NAACOS releases in-depth analysis of the final Pathways to Success rule

  • Interactive spreadsheet to estimate shared savings and losses under the various track options 

  • NAACOS Webinar Review of ACO Pathways to Success Provisions included in the Medicare Physician Fee Schedule Rule 

  • NAACOS Review of ACO Pathways to Success Provisions included in the Medicare Physician Fee Schedule Rule 

CMS Resources

Proposed Rule

  • NAACOS submitted a 39-page comment letter on the proposed CMS Pathways to Success rule
    • NAACOS press release on its final comments and related ACO poll about proposed Pathways to Success rule 
  • A survey of all current MSSP participants polled ACOs’ feelings about the proposed rule 
  • The popular Regulatory Update from the NAACOS fall conference provides another review of the proposed Pathways to Success rule and other policy updates. 

  • NAACOS Statement on the proposed rule after the initial Aug. 9 release 

News and Advocacy


  • Highlights of ACO results from 2019 and overall savings since 2012


  • CMS finalizes several MSSP-related policies in the final 2019 Physician Fee Schedule and MACRA rule here. A CMS factsheet is here
  • Lawmakers ask for key changes in final Medicare ACO regulation
  • NAACOS member testified before a House subcommittee to discuss the proposed rule 

  • ACOs Saved Medicare $2.7 Billion from 2013-2016
  • A NAACOS-commissioned study showed ACOs saved Medicare $1.84 billion from 2013 to 2015
    • 2017 performance data from CMS shows positive results, prompting NAACOS statement

    • NAACOS resource includes highlights of the 2017 MSSP results