April 3, 2026

This week, CMS announced important policy changes to protect ACOs from fraudulent, wasteful, and abusive spending in 2025—marking a meaningful step forward for the ACO community.

Key actions include: 

These changes will provide critical financial relief and improve benchmarking accuracy. They also reflect the strong, coordinated advocacy of NAACOS members, whose efforts were instrumental in securing this outcome. 

However, significant gaps remain. 

CMS declined to take similar action on skin substitute spending within MSSP, citing the truncation factor as sufficient protection for nearly 90 percent of ACOs. This leaves approximately 10 percent of ACOs, often those serving the most vulnerable populations, exposed to substantial and inappropriate costs. 

While CMS suggests ACOs pursue reopening determinations to address improper payments, this reactive approach is insufficient. A more proactive, system-level solution is needed. NAACOS will be engaging directly with affected ACOs to coordinate next steps and advocate for additional relief. 

More broadly, these updates do not resolve long-standing challenges in identifying and addressing fraud, waste, and abuse. NAACOS continues to urge CMS to strengthen its Significant, Anomalous, and Highly Suspect (SAHS) policies in the upcoming Physician Fee Schedule by: 

NAACOS remains committed to supporting members in monitoring and addressing fraud, waste, and abuse. If you are observing suspicious trends, please contact [email protected] : 

This week, CMS released the LEAD (Long-term Enhanced ACO Design) model request for applications; CMS will be hosting a webinar on LEAD on April 9 at 2:00 pm ET (Register). NAACOS will refocus our REACH Roundtable to cover both REACH and the LEAD Model. Beginning in May, the roundtable will be held the Fourth Thursday of every month at 12:00 pm ET. Once the request for applications is released, we will be working to ensure that members are supported as they evaluate the model. Here are several opportunities to get involved: 

NAACOS continues to urge the Administration to ensure stability in ACO programs by fixing inaccurate trend adjustments; holding ACOS harmless for fraud, waste and abuse; and addressing the benchmark ratchet. Last month NAACOS sent a sign-on letter with more than 120 members asking CMS to address these issues and embrace innovation in MSSP. 

We encourage members to share their perspectives on these recommendations with CMS. Check out the modernizeACOs.org for more information and contact [email protected] if you need assistance in your outreach to the Administration. 

Share the contact information of your organization’s lobbyists or government relations (GR) professionals with our advocacy team. This will help NAACOS improve coordination and alignment on advocacy efforts with Congress and the administration. Thank you for your support in strengthening our collective voice. Please send a list with contact information to [email protected]. 

Reps. Claudia Tenney (R-NY) and Brad Schneider (D-IL) introduced a bill to establish a permanent full-risk Medicare ACO program, similar to the ACO REACH model. NAACOS supports this effort as an important step toward reducing barriers for organizations ready to take on downside risk. We also see this as an opportunity to continue working with CMS on targeted improvements to ACOs that will enable more providers to successfully transition to risk and sustain long-term participation in value-based care. 

House and Senate Republican leaders are discussing using budget reconciliation to pass another government funding package that would not require bipartisan support from congressional Democrats. The bill would likely focus on providing additional funding for Homeland Security programs and defense issues related to the ongoing conflict in Iran. The cost of the legislation would likely be offset with additional funding reductions to federal health programs with a focus on addressing fraud, waste, and abuse. 

Earlier this year, the Republican and Democratic co-chairs of the House Doctors Caucus issued a request for information on how to reform Medicare’s physician payment system. NAACOS has been engaging with the caucus and provided recommendations on how to incentivize and improve adoption of APMs. The caucus is collaborating on releasing legislative proposals this spring to build support for a comprehensive overhaul of physician payment. The House Energy and Commerce and Ways and Means Committees will also continue to hold hearings on health care affordability. 

CMS recently published the application and change request cycle timelines for PY 2027 of the MSSP. The Phase 1 application window will be open from June 6 through June 23, 2026, at 8:00 pm ET. ACOs must submit the initial application in this window to be considered for a new contract beginning January 1, 2027—whether they are new ACOs, renewing, or re-entering. Currently participating ACOs may also utilize the Phase 1 submission window to elect a different beneficiary assignment methodology for PY 2027. Key application deadlines can be found here and additional details are available in the application toolkit. 

CMS has announced the Accelerating State Pediatric Innovation Readiness and Effectiveness Model (ASPIRE) Model to help children up to age 21 with complex medical and behavioral needs live healthier lives through whole-person care delivery in Medicaid and CHIP, including wrap-around services to address physical and behavioral health needs. This 10-year, voluntary model will be open to up to five states through cooperative agreement funding. These states will partner with “accountable entities” including ACOs and managed care plans, to manage total costs of care and improve outcomes for covered Medicaid and CHIP enrollees. A notice of funding opportunity will be available in 2026. The model’s design was built on lessons learned from the Integrated Care for Kids Model and the goals of the model are highlighted in the ASPIRE Model journey map. 

Register today for the upcoming Southwest Virtual Mid-Year Meeting on May 19, 2026. 

Join the conversation on important topics such as balancing access, utilization, and quality in risk-based contracts, as well as strengthening community care hub partnerships across the Southwest.  You will hear from organizations such as the Administration for Community Living (ACL) and Dr. Patrick Vinck, MD, Oak Street Health, and gain valuable perspectives, real-world examples, and opportunities to connect with peers working to improve outcomes and advance collaborative solutions. 

Register now for the Spring 2026 Conference at the Hilton Baltimore Inner Harbor. The main conference, taking place April 23–24, will feature insights from leading health care experts and five senior CMS officials, offering an in-depth look at the strategies shaping today’s health care transformation. Attendees will benefit from engaging presentations, panel discussions, and valuable networking opportunities with peers, speakers, and vendors to connect, collaborate, and share best practices. 

Kick off the experience with an optional pre-conference workshop on Wednesday, April 22, from 1:00–5:00 pm. These workshops run concurrently and require separate registration from the main conference. Workshops available are: 

Don’t miss your chance to be part of three days filled with learning, connection, and growth. Register now and make sure you’re part of the conference everyone will be talking about! 

Can’t attend in person? Individuals unable to attend the conference in person can participate in the virtual conference. The virtual conference includes all of the breakout sessions and plenaries as well as the sponsored breakfasts. Virtual participants also receive six months of access to the recordings of the sessions so that you don’t miss out on any of the sessions! 

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