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 every thing ACOs need to know about the final changes.   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 releases in-depth analysis of the final Pathways to Success rule

  • Frequently Asked Questions on the Final Pathways to Success Rule

  • NAACOS statement on the final Pathways to Success rule

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

Proposed 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. 

News and Advocacy


  • CMS issues guidance on the new Beneficiary Incentive Program

  • NAACOS urges CMS to push Feb. 19 MSSP application deadline

  • The application deadline for July 1, 2019 starts is February 19

  • CMS released guidance on apply for the new waiver from the Skilled Nursing Facility (SNF) 3-Day Rule

  • CMS releases final ACO 'Pathways to Success' rule on 12/21/18

  • Notice of Intent to Apply for July 1, 2019 start in new ‘Pathways to Success’ structure of the MSSP due April 18, 2019

  • CMS finalizes several MSSP-related policies in the final 2019 Physician Fee Schedule and MACRA rule here. A CMS factsheet is here

  • The November 1 CMS ACO Spotlight Newsletter provides an update on MSSP changes in the 2019 Physician Fee Schedule and Quality Payment Program final rule, including updates on extending contracts that expire at the end of 2018 for another six months. 
  • Lawmakers ask for key changes in final Medicare ACO regulation 
  • 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 
  • NAACOS member testified before a House subcommittee to discuss the proposed rule 
  • A NAACOS-commissioned study showed ACOs saved Medicare $1.84 billion from 2013 to 2015 
  • NAACOS Statement on the proposed rule after the initial Aug. 9 release