News Release
September 6, 2022 

NAACOS Responds to Proposed Changes to
Medicare’s Largest ACO Program
If Finalized, the Rule Would Help Grow ACO Participation

WASHINGTON — In its comments to proposed changes to Medicare’s largest value-based care program, the National Association of ACOs (NAACOS) expressed gratitude to the Centers for Medicare and Medicaid Services (CMS) for efforts to grow accountable care organizations (ACOs). Numerous changes included in the proposed 2023 Medicare Physician Fee Schedule would both encourage new ACOs to enter into the Medicare Shared Savings Program and incent current ACOs to stay in the program. 

Among the many positive changes ACOs would see if the rule were finalized, certain new ACOs would be eligible for advanced payments to help with startup costs, ACOs would be given more time before advancing to higher levels of risk, CMS would remove the pass/fail approach to quality scoring and return to a sliding scale that’s applied to shared savings, some ACOs would have greater opportunities to achieve shared savings, in addition to other positive changes to benchmarking and risk adjustment. 

“CMS is putting action behind its goal set last year to have all Medicare patients in a relationship with a provider accountable for their quality and total cost of care by 2030,” said NAACOS President and CEO Clif Gaus, Sc.D. “These changes will certainly help reach their goal and improve our health system by growing the footprint of ACOs. Since 2018, ACO growth has been flat, but improvements made by CMS will reverse that trend. We encourage CMS to finalize this rule with some modifications” 

There are some parts of the rule that need to be changed before finalized. While is great to see that CMS is taking steps to address the long-term problem of ACO benchmarks falling as the ACO lowers the cost of their patients, setting a national growth factor would hurt roughly a third of ACOs. Medicare spending varies by region, ACO benchmarks cannot be set with one national figure. 

“An ACOs’ success can’t be decided simply by its geography. Instead, CMS should use a regional update factor on which to base administrative benchmarks,” Gaus said. “We greatly appreciate CMS’s efforts to address the ‘ratchet effect’ and look forward to continued collaboration with the Agency to determine best approaches for administratively set benchmarks” 

Since 2012, ACOs have saved Medicare $13.3 billion in gross savings and $4.7 billion in net savings. Importantly, data show these ACOs continued to provide high-quality care and yield satisfied patients. Importantly, data show these ACOs continued to provide high-quality care and yield satisfied patients. Today, ACOs care for nearly 20 percent of all Medicare patients and nearly a third of traditional Medicare patients. Importantly in Medicare, ACOs allow patients to maintain their choice of provider, and there are no network restrictions or use of prior authorization. 



David Pittman
Senior Policy Advisor
202-640-2689 or [email protected]