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Organization Evidence Review

National Association of ACOs

National ACO and value-based-care membership association

As of July 24, 2026United StatesFiscal year ended December 31, 2024Filed Form 990Primary constituency: Accountable care organizations and other value-based-care provider entities; provider members, not individual physicians, hold formal membership rights.

Path A · Quick read

One uniform surface for comparison; detailed evidence is below.

Core comparison profile

Three strongest findings

  1. FY2024 revenue reconciles to $6.08 million, but ultimate payer identity does not.
  2. Provider members may vote and serve in governance; paid partners do not receive the same formal voting rights.
  3. Current conduct generally tracks the ACO and value-based-care mission, with important limits on outcome attribution.

Evidence supporting reliance

  • Membership, partner rules, board, staff, filings, advocacy, and political activity are publicly documented.
  • Current policy activity is specific and closely tied to accountable-care design and physician payment.
  • Formal separation between provider-member votes and partner access is a meaningful governance safeguard.

Reasons for caution

  • Ultimate payer mix and concentration are undisclosed.
  • Paid sponsorship and partner access pathways exist even though partners lack formal votes.
  • Public reach counts and outcome claims require date and attribution qualification.

Material unknowns

  • Who paid the $5.90 million program-service revenue and in what concentration.
  • How physician segments participate, vote indirectly, and evaluate support.
  • Current complete bylaws, minutes, conflict files, and audited statements.

Report card

The score summarizes assessed evidence; evidence coverage is reported separately.

Transparency
9/15
Funding independence
NE
Mission alignment
17/20
Governance
12/15
Breadth
NE
Accountability
7/10
Legal / ethical
8/10
Outcomes
4/5

Official accounting revenue mix

Program services (97.0%)
$5.90M
Investment income (1.8%)
$112,321
Other revenue (1.1%)
$68,281
Accounting categoryAmountShare
Program services$5.90M97.03%
Investment income$112,3211.85%
Other revenue$68,2811.12%
Total$6.08M100.00%
$6.08MLatest reported revenue
$5.75MLatest reported expenses
$3.43MNet assets / reserve context

Payer and funding-source visibility

Minimum classified: 0.0%Not allocated by payer/source: 100.0%

The filing reports nearly all revenue as program-service revenue but does not identify which ACOs, health systems, physician groups, vendors, or other entities paid it. Paid partners may receive access or visibility but do not hold provider-member voting rights.

Identity, alignment, and influence at a glance

Primary constituency: Accountable care organizations and other value-based-care provider entities; provider members, not individual physicians, hold formal membership rights.

Physician alignment: Role dependent; strongest for ACO and value-based-care leaders rather than individual physician representation.

Funding model: Organizational membership and event/program support; individual physician funding is not the core model.

Primary influence: See the detailed authority and influence analysis.

Executive summary

NAACOS is a national organization for ACO and value-based-care provider entities rather than a direct individual-physician membership society. FY2024 revenue was $6.08 million and was almost entirely classified as program-service revenue, but the public filing does not identify the ACOs, health systems, physician groups, or commercial entities that supplied it. Provider members hold formal voting rights, while commercial partners have access and sponsorship pathways without the same vote. NAACOS's advocacy and education generally align with accountable-care and value-based-payment goals. Its normalized C grade reflects good mission alignment and a useful provider-governance distinction, tempered by unresolved payer concentration, indirect physician representation, and limited independent outcome attribution.

One sentence: NAACOS is a mission-aligned ACO advocacy organization with provider-member voting rights, but it represents organizations rather than physicians directly and does not disclose who ultimately supplies most revenue.

Path B · Detailed evidence review

Every organization uses the same twelve evidence sections and order.

1Identity, Mission, and ScopeFact pattern

Organization type: National ACO and value-based-care membership association

Primary constituency: Accountable care organizations and other value-based-care provider entities; provider members, not individual physicians, hold formal membership rights.

Mission: Advance accountable care and value-based payment by supporting ACOs and advocating for policies that improve care and lower cost.

Scale: Nearly 500 ACO and value-based-care entities are reported in current official materials.

2Leadership and Decision AuthorityCurrent roles
LeaderCurrent roleAuthority context
Jen MooreBoard chairProvider-member governance
Arshad Rahim, MDChair-electProvider-member governance
Melanie MatthewsPast chairBoard governance
Stephen NuckollsTreasurerFinancial oversight
Emily BrowerChief executive officerOperational leadership
Decision-rights rule: Formal titles do not automatically reveal operational control. The review separates elected governance, board authority, executive execution, member votes, and affiliate authority.
3Financial SupportAccounting view

Period: Fiscal year ended December 31, 2024
Status: Filed Form 990

Accounting categories are presented exactly as reported.

$6.08MLatest reported revenue or operating income
$5.75MLatest reported expenses
$3.43MLatest reported net assets / reserve context
Program services (97.0%)
$5.90M
Investment income (1.8%)
$112,321
Other revenue (1.1%)
$68,281
Accounting categoryAmountShare
Program services$5.90M97.0%
Investment income$112,3211.8%
Other revenue$68,2811.1%
4Payer Identity and Unknown FundingPayer guardrail
Identified: 0.0%Not allocated: 100.0%

The filing reports nearly all revenue as program-service revenue but does not identify which ACOs, health systems, physician groups, vendors, or other entities paid it. Paid partners may receive access or visibility but do not hold provider-member voting rights.

Guardrail: An accounting category is not the same thing as an ultimate payer. No physician-versus-hospital pie is shown unless mutually exclusive payer classes can be supported.
5Related Organizations and Money FlowsEntity separation
Entity or relationshipRelationship typeWhy it matters
NAACOS Action FundSeparate political committeePolitical receipts and spending remain distinct.
Institute for Accountable CareRelated policy and research organizationSeparate governance and finances must not be combined with NAACOS.

Related entities, foundations, PACs, trusts, networks, and LLCs remain financially and legally separate unless a documented transfer is included in the reviewed organization’s accounts.

6Top InfluencersEvidence classified
InfluencerEvidence classificationEvidence-supported relevance
Provider-member ACOsDirectly documentedHold formal membership and governance rights.
Board and CEODirectly documentedSet and execute policy.
Commercial partners and sponsorsDirectly documented relationshipReceive access and visibility; financial magnitude is not fully allocated.
Federal payment agenciesDirectly documented external environmentCMS policy materially shapes the organization's agenda but does not constitute organizational control.

Interpretation: A documented relationship may create influence or incentives; it does not by itself establish control, misconduct, or improper capture.

7Mission Versus ConductAlignment test
Mission or public commitmentAlignment assessmentDocumented action or tension
ACO and value-based-care advocacyAlignedCurrent policy activity directly tracks mission.
Physician payment reformGenerally alignedPositions support sustainable participation in value-based models.
Individual physician voiceMixedRepresentation is primarily through provider organizations.
Partner access safeguardsPartially alignedVoting distinction exists, but receipts and influence pathways are not fully transparent.
8Physician and Member RepresentationConstituency test
Physician or member segmentEvidence-supported assessment
ACO and value-based-care organizationsPrimary formal constituency
Physician-led ACOsDirect organizational pathway
Employed physiciansIndirect representation through organizations
Independent physiciansRepresentation depends on ACO structure
Specialty and rural segmentsParticipation and outcomes not quantified
Membership-count rule: Total membership does not prove equal participation, voting power, financial contribution, or benefit across segments.
9Legal, Regulatory, and Ethical RecordStatus and outcomes

Legal, regulatory, and ethical record

No material final adverse enforcement finding against NAACOS was identified in the reviewed sources. Policy advocacy and political activity are separately disclosed and are not themselves adverse findings.

Outcome accountability

NAACOS cites accountable-care savings and quality evidence, but system-level results cannot be attributed solely to the association.

10Report Card MethodologyNormalized rubric

Normalized score: 76/100 (C). Raw evaluated points: 57/75. Evidence completeness: 75%.

DimensionScoreGradeInterpretation
Financial Transparency and Source Identification9/15D60% of dimension maximum
Funding Independence and Concentration RiskNENENot evaluated
Mission-to-Action Alignment17/20B85% of dimension maximum
Physician or Member Governance and Representation12/15B80% of dimension maximum
Breadth of Support Across Physician SegmentsNENENot evaluated
Leadership, Conflict Management, and Accountability7/10C70% of dimension maximum
Legal, Regulatory, and Ethical Record8/10B80% of dimension maximum
Outcomes and Public Accountability4/5B80% of dimension maximum
Why two percentages? The normalized score summarizes performance on evaluated dimensions. Evidence completeness separately measures how much of the desired evidence was sufficiently current and documented. They are intentionally not the same number.

Read the complete standardized methodology.

11Limitations and Unanswered QuestionsVisible caveats
  • No payer-class reconciliation.
  • Provider counts vary by date and definition.
  • Individual physician voice is indirect.
  • Partner receipts, concentration, and influence safeguards are incomplete.
  • Audited statements were not located in the review set.

Information most likely to change this assessment: current audited financials, mutually exclusive payer-class schedules, top-funder concentration, current bylaws and conflict records, segment-level participation, and independently validated outcomes.

12Verification and Review StatusPublication gate
Verification completed: current leaders and major organizational roles were checked against current official sources; financial totals and percentages were independently recalculated; related entities were kept separate; and allegations were not treated as findings.

Publication status: Public review. A last-link check and final editorial approval are required before each release.

Editorial independence: The reviewed organization did not approve, edit, or veto the findings or score. Factual corrections may be submitted through the published corrections process.

Scope: Verification is limited to publicly accessible records. Private contracts, nonpublic minutes, sealed proceedings, and undisclosed conflicts are outside the available evidence.

Sources, Methods & Verification · 21 references

Source rule: Primary and official records were preferred. Accounting categories were not converted into payer identities. Related entities were kept separate. Allegations were not treated as findings.

Verification: current leaders and major financial arithmetic were checked for this publication batch. Material corrections and future updates follow the published verification process.

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