Shared Savings pushes risk, but experts debate the impact

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article examines final 2026 Medicare physician fee schedule updates tied to the Medicare Shared Savings Program and broader accountable care organization policy. It is relevant to ACO leaders, physician groups, health system administrators, and coding or compliance professionals who track Medicare payment-model changes. The discussion focuses on CMS changes affecting participation in risk tracks, beneficiary assignment, quality measurement, and special program exceptions, along with expert reaction to whether the revisions will encourage more ACOs to move into two-sided risk.

Why This Topic Matters

The policy changes described here may affect ACO participation strategy, attribution counts, quality-score reporting, and operational planning for organizations involved in Medicare value-based care.

Article Sections

  1. Medicare Shared Savings Program changes in the final 2026 physician fee schedule

    Overview of the CMS updates included in the final rule and the program areas they affect. The section sets up the article’s discussion of participation, risk, and attribution changes.

  2. Experts see risk glass half full

    Perspectives from industry and legal experts on whether the revised structure will encourage more ACOs to accept risk. This section discusses general reactions from different stakeholder viewpoints.

  3. BHI, CoCM now attributable

    Discussion of beneficiary assignment changes involving behavioral health integration and psychiatric collaborative care management services. The section also introduces CMS’s request for information related to primary care payment arrangements.

  4. SDOH kept, equity cut

    Summary of changes affecting social determinants-related reporting and the removal of a health equity adjustment. This section covers related quality-score and benchmark policy revisions.

  5. Note other changes

    Additional program updates involving quality reporting, Medicare CQM participation, and extreme circumstance policies. The section highlights other operational changes within the Shared Savings Program.

What You Will Learn

  • How CMS is changing Medicare Shared Savings Program participation pathways for ACOs
  • What the final rule says about beneficiary assignment and primary care service definitions
  • Which quality-reporting and scoring policies are being revised for Shared Savings Program participants
  • How CMS is treating certain exception and disruption policies for affected ACOs
  • Why stakeholders say the changes may or may not accelerate movement into two-sided risk

Who Should Read This

  • Accountable care organization leaders
  • Physician practice administrators
  • Health system compliance teams
  • Medicare payment policy professionals
  • Coding and reimbursement analysts
  • Value-based care consultants

Codes Discussed


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