As of January 1, 2024, the Shared Savings Program boasted 480 ACOs with over 634,000 providers and organizations, serving more than 10.8 million beneficiaries—making it the largest value-based care program in the U.S.
Recent policy updates from the CY 2024 PFS final rule and CY 2025 PFS proposed rules are set to expand the program significantly over the next decade. These changes aim to increase ACO participation and the number of beneficiaries assigned to ACOs by up to four million by 2034. The new policies focus on enhancing growth, equity, and alignment across care initiatives, aligning with CMS’s goal of having all Traditional Medicare beneficiaries in a quality-focused care relationship by 2030.
Prepaid Shared Savings
One notable change is the introduction of a “prepaid shared savings” option for ACOs with a strong history of earning shared savings. Approved ACOs can receive advance payments to invest in services like meals, dental care, vision, hearing, and Part B cost-sharing support for beneficiaries or to enhance care coordination through staffing and infrastructure.
ACO Quality Measure Reporting
Additionally, quality measurement reporting requirements will be ramped up. The most wide-ranging change involves eCQM reporting for a much larger population of patients.
- APP Plus Quality Measure Set: Introduction of the APM Performance Pathway (APP) Plus quality measure set, required for MSSP ACOs starting in 2025. This will replace the existing APP quality measure set. Starting in the performance year 2025 ACOs will be evaluated based on eight measures from the APP Plus quality measure set:
- five eCQMs/Medicare CQMs
- CAHPS for MIPS survey
- two administrative claims-based measures
- Incremental Growth: The measure set will grow from six to eleven measures over the next few performance years.
- Streamlined Reporting: ACOs will report using electronic clinical quality measures (eCQMs) or Medicare Clinical Quality Measure collection types, eliminating the use of MIPS CQMs but requiring quality reporting for an increased patient population, potentially across multiple disparate EHRs.
Proposed APP Plus Quality Measure Set for Shared Savings Program ACOs:
| Quality # | Measure Title | Collection Type | Performance Year Phase In |
| 321 | CAHPS for MIPS | CAHPS for MIPS Survey | 2025 |
| 479 | Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Eligible Clinician Groups | Administrative Claims | 2025 |
| 484 | Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions | Administrative Claims | 2025 |
| 001 | Diabetes: Hemoglobin A1c (HbA1c) Poor Control | eCQM/Medicare CQM | 2025 |
| 134 | Preventive Care and Screening: Screening for Depression and Follow-up Plan | eCQM/Medicare CQM | 2025 |
| 236 | Controlling High Blood Pressure | eCQM/Medicare CQM | 2025 |
| 113 | Colorectal Cancer Screening | eCQM/Medicare CQM | 2025 |
| 112 | Breast Cancer Screening | eCQM/Medicare CQM | 2025 |
| 305 | Initiation and Engagement of Substance Use Disorder Treatment | eCQM/Medicare CQM | 2026 |
| 487 | Screening for Social Drivers of Health | eCQM/Medicare CQM | 2028 |
| 493 | Adult Immunization Status | eCQM/Medicare CQM | 2028 |
Scoring Adjustments
MIPS Quality Scores: ACOs will be scored on all measures in the APP Plus set based on APP scoring policies.
- eCQM Incentives: Starting in 2025, an adjustment will award points for each submitted eCQM that meets requirements, encouraging ACOs to report electronically.
The Shared Savings Program will also refine its financial methodologies to better support ACOs, especially those serving underserved communities. This includes a new health equity benchmark adjustment and a revised approach to handling improper payments and anomalous billing activities. Changes are also proposed to simplify beneficiary information notifications and align program policies with current antitrust guidelines.
CMS requested comments to be submitted no later than September 9, 2024. Typically, CMS publishes the final rule in the Federal Register a couple of months after closing the comment period. For more detailed information and to access the full text of the proposed rule, visit the official CMS website and review the publication in the Federal Register.
Stay up to date with DHIT as we dive deeper into the changes for ACOs in 2025 once the final rule is published.
