KEY SIGNAL
Physician payment
The national dollar multiplier starts lower in 2027.
NEGATIVE
DETAIL
Physician fee schedule
QP: $33.1693 (-1.19%)
Non-QP: $32.8409 (-1.68%)
Source: CMS-1848-P and official supporting files. Proposed, not final.
CY 2027 MPFS proposed rule: This is a mixed redistribution rule, not a uniform physician loss. The conversion factors decline. Primary care is relatively protected, while the clearest losses concentrate in office-based procedural specialties. CMS proposes meaningful MSSP benchmark and quality-reporting changes, but BASIC Level E versus ENHANCED economics still require ACO-specific modeling. The rule also tightens modifier-25 payment, remote-monitoring staffing, QP treatment, and specialty accountability. Everything remains proposed until the final rule.
What to know first
This is a mixed redistribution rule, not a uniform physician loss. The multiplier is lower; the operational and specialty effects are much more uneven.
KEY SIGNAL
MSSP financial package
Overall win. Eligible January 1, 2027 applicants may receive a time-limited post-final-rule window to revisit BASIC Level E versus ENHANCED if the proposal is finalized.
STRUCTURALLY POSITIVE; EARNINGS MIXED
DETAIL
MSSP Level changes
Savings protection and ACPT guardrails strengthen MSSP benchmarks program-wide. Separate regional-adjustment changes favor BASIC Level E over ENHANCED: Level E's shared-savings rate rises from 50% to 60%, while the proposed maximum positive regional-adjustment weight falls only for affected ENHANCED ACOs. If finalized, CMS plans a time-limited post-final-rule window for January 1, 2027 applicants to change their BASIC-versus-ENHANCED selection in either direction.
Source: CMS-1848-P and official supporting files. Proposed, not final.
KEY SIGNAL
PY 2025 shared-savings timing
CMS expects financial results in November and shared-savings payments in December. The recalculation should leave affected ACOs unchanged or improve their result.
DELAYED; LIKELY FAVORABLE
DETAIL
MSSP Surplus Payment
Because the ACPT guardrail would apply retroactively to PY 2025, CMS would hold PY 2025 reconciliation until the final rule. Financial results are expected in November 2026 and shared-savings payments in December 2026. CMS states affected ACOs would benefit from the recalculation or be unaffected.
Source: CMS-1848-P and official supporting files. Proposed, not final.
KEY SIGNAL
Quality reporting
Less reporting burden may be possible, but vendor capability still must be proven.
EASIER REPORTING, BUT VENDOR CAPABILITY MUST BE PROVEN
DETAIL
Quality: eCQM / dQM
CMS is proposing fewer required quality measures, a new option to report only on assigned Medicare patients, and simpler ACO-level CEHRT requirements. This could reduce reporting work, but ACOs should not choose the new option until their EHR and registry vendors prove they can identify the right patients, meet the 75% completeness requirement, submit the data correctly, and support an audit.
Source: CMS-1848-P and official supporting files. Proposed, not final.
KEY SIGNAL
Specialty effects
The losses are concentrated, not universal.
HIGHLY UNEVEN
DETAIL
Specialists
Behavioral health rises. ENT, dermatology, orthopedics, hand, podiatry, colorectal and ophthalmology may have slight negative vs flat impact.
Source: CMS-1848-P and official supporting files. Proposed, not final.
KEY SIGNAL
Primary care
PCPs do better than average, but the base-rate decline absorbs the national gain.
RELATIVELY PROTECTED
DETAIL
Primary care
Family practice and internal medicine are +1% in CMS Table D-B5; approximately -0.7% QP / -1.2% non-QP after the outside statutory factor.
Source: CMS-1848-P and official supporting files. Proposed, not final.
KEY SIGNAL
LEAD / ACCESS context
LEAD is relevant to this rule; ACCESS is outside the scope of this proposed rule.
RULE CONTEXT ONLY
DETAIL
LEAD / ACCESS
LEAD is discussed because proposed MOD2 would also be available to LEAD Participant Providers. ACCESS is outside the scope of this proposed rule.
Source: CMS-1848-P and official supporting files. Proposed, not final.
KEY SIGNAL
Medicare Advantage
This rule is not a basis for saying MA is helped or hurt overall.
NO BROAD RATE CONCLUSION
DETAIL
Medicare Advantage
No general CY 2027 Medicare Advantage rate or risk-adjustment analysis is included. CMS addresses MSSP assignment of some MA-to-Original Medicare switchers beginning PY 2028.
Source: CMS-1848-P and official supporting files. Proposed, not final.
01 How the Medicare payment math changes
The conversion factor is only the final multiplier. CMS is also changing RVUs, practice-expense allocation, and claim rules underneath it.
Payment and claim mechanics
| Change | What CMS proposes | Practical interpretation | Simplified |
|---|---|---|---|
| Conversion factors (CF) | QP $33.1693 (-1.19%) Non-QP $32.8409 (-1.68%) | Detailed Tables D-B1 and D-B2 remove the one-year 2.50% CY 2026 increase, then apply the 0.75% QP or 0.25% non-QP update plus a +0.53% budget-neutrality adjustment. | Everyone starts lower; QPs lose less. |
| Accuracy alert | The opening executive summary appears to swap the CY 2026 comparison bases. The detailed tables use $33.5675 for QP and $33.4009 for non-QP and are internally coherent. | Use the detailed Regulatory Impact Analysis tables for forecasts, not the mislabeled opening sentence. | The detailed math, not the opening typo, controls this analysis. |
| G2211 splits into MOD1 / MOD2 | CMS would retire G2211 as a separate add-on code and replace it with two claim-line modifier levels on eligible office/outpatient or home/residence E/M services. MOD1 is a placeholder for 16% of the associated E/M total RVUs. MOD2 is a placeholder for 32%; final two-character modifiers would be assigned if finalized. | MOD1 follows the current G2211 longitudinal-care standard and is available to any qualifying clinician; it is not limited to non-ACO clinicians. Depending on the E/M level, payment may be roughly flat or lower than today's G2211. MOD2 is limited to eligible MSSP, ACO Primary Care Flex and LEAD clinicians, including qualifying specialists, and creates a meaningful increase. ACO participation alone is not enough: the record must support the continuing focal-point or serious/complex-condition relationship. The current modifier-25 restriction generally continues, except with an AWV, vaccine administration or another Part B preventive service. | Eligible ACO clinicians get the larger longitudinal-care payment. CMS is steering more fee-for-service support toward value-based care. |
| Same-day office E/M plus global procedure | For a separately identifiable office/outpatient E/M with modifier 25 and a same-day 0-, 10- or 90-day global procedure by the same physician or same group, the highest-priced affected service would be paid at 100% and all other affected services at 50%. | A shared group TIN creates cross-clinician testing scenarios. Use local claims to model the effect; CMS Table D-B5 already incorporates the national modeled effect. CMS also seeks comment on a 25% alternative. | One visit plus a procedure may pay less even when different group clinicians are involved. |
| Practice expense (PE) methodology | PE is Medicare payment for practice resources such as staff, rent, supplies, equipment and administration. CMS would add both work RVUs and clinical-labor PE RVUs to the indirect allocator for most services, except 010- and 090-day global codes. | This changes the relative overhead value among codes, specialties and sites; it is not a uniform office cut. | CMS is changing how overhead is divided across services. |
| IPCI removal and PE stabilization | CMS would phase out the Indirect Practice Cost Index over two years, applying half the measured variation in 2027. A new +/-5% annual PE-RVU stabilizer would apply with exclusions and before the statutory total-RVU phase-in. | The 5% limit is not a total-payment cap. New/revised, newly nationally priced and revalued codes may be excluded, and final total RVU changes can exceed 5%. | The PE math gets a shock absorber, not a guaranteed 5% payment limit. |
| SNF / NF E/M PE | For codes 99304-99310 and 99315-99316, CMS would set facility PE equal to nonfacility PE regardless of whether the beneficiary is in a Part A stay. | This corrects a payment difference caused by Part A status, not a general office-visit policy. | The same nursing-facility visit gets the same overhead value. |
| Efficiency adjustment / 99024 - continuation items, not new cuts | The 2.5% efficiency adjustment was finalized for CY 2026 for selected non-time-based services and is recalculated every three years. CY 2027 adds no new across-the-board efficiency cut, but the existing adjustment remains embedded in affected valuations and the annual exemption file continues. Separately, CMS proposes pausing the no-pay 99024 postoperative data collection and publishing a public-use file showing how surgical work RVUs would change if postoperative visits were removed from global-package valuations. | Do not subtract another 2.5% from 2027 forecasts or unbundle routine postoperative care. The pause reduces reporting burden, but the arithmetic file is a warning signal that CMS is preparing possible future global-package revaluation. | Nothing new to subtract this year and one less reporting task. But CMS is showing the math for a possible future cut to global surgical payments. |
02 Specialty payment signal
CMS national estimates show real winners and concentrated losses. They are directional, not local forecasts.
| Specialty or group | CMS national estimate from proposed 2027 PFS changes | Approx. net after the temporary 2026 increase expires QP / non-QP | Practical read |
|---|---|---|---|
| Clinical social worker | +12% | +10.1% / +9.5% | Large increase |
| Clinical psychologist | +11% | +9.1% / +8.6% | Large increase |
| Geriatrics; diagnostic testing facility | +4% | +2.2% / +1.7% | Modest increase |
| Psychiatry; interventional radiology; PT/OT; radiation oncology; vascular surgery | +3% | +1.2% / +0.7% | Modest increase |
| Endocrinology; nurse practitioner; radiology; nuclear medicine | +2% | +0.3% / -0.2% | About flat |
| Family practice; internal medicine; cardiology | +1% | -0.7% / -1.2% | Relatively protected |
| General surgery; nephrology; neurology; pulmonary; oncology; infectious disease; critical care | 0% | -1.7% / -2.2% | Moderate decline |
| Gastroenterology; OB/GYN; rheumatology | -1% | -2.7% / -3.2% | Moderate decline |
| Urology; neurosurgery; interventional pain; optometry | -2% | -3.7% / -4.2% | Moderate decline |
| Ophthalmology; physician assistant; audiology | -3% | -4.7% / -5.1% | Large decline |
| Colon and rectal surgery; podiatry | -4% | -5.6% / -6.1% | Large decline |
| Hand surgery | -5% | -6.6% / -7.1% | Large decline |
| Orthopedic surgery | -7% | -8.6% / -9.0% | Very large decline |
| Dermatology; otolaryngology (ENT) | -9% | -10.6% / -11.0% | Very large decline |
03 Operational changes
The rule creates specific claim, documentation, supervision, staffing, and vendor changes.
| Change | What CMS proposes | Operational interpretation | Simplified |
|---|---|---|---|
| Telehealth through 2027 / BB-BC modifiers | CAA 2026 extends core geographic, originating-site and practitioner flexibilities through December 31, 2027; audio-only authority and the mental-health in-person delay run to January 1, 2028. BB and BC identify specified virtual-platform and incident-to telehealth arrangements beginning January 1, 2027 and do not affect payment. | Keep current telehealth workflows, update claims logic after guidance and maintain a 2028 contingency. | Core telehealth stays available in 2027; claims labeling changes. |
| RPM / RTM | RTM would become established-patient-only. Both RPM and RTM would require a separately reportable in-person or telehealth initiating visit by the billing practitioner, and the service must be discussed. Billable clinical-staff time would require direct employment by the practitioner/practice. CMS also proposes PE revaluation; a separate solicitation considers four bundled G-codes. | Inventory all workers, vendors, devices and initiating visits. Do not treat the possible four-code bundle as a finalized proposal. | Third-party clinical-staff models may stop qualifying, and payment inputs may fall. |
| Shared Medical Appointment - GSMAS | Proposed 60-minute voluntary session for 2-10 patients with common lifestyle-modifiable condition(s), led and billed by a physician or qualified NPP. Requires a professional service within the prior 12 months from the billing clinician or exact same specialty/subspecialty in the group, patient and confidentiality consent, individualized and group documentation, and may be telehealth. Other services delivered as part of the session are not separately billed. | Potential pilot for diabetes, obesity, hypertension or hyperlipidemia. The proposed 45 minutes of work is valuation, not a billing-time threshold. | One clinician may bill individualized care delivered in a small group, with substantial guardrails. |
| Vaccine adverse-effects management - GADV1 | Proposed add-on code for each 15 minutes personally performed by a physician/QHP with an eligible office/outpatient or home/residence E/M. The clinician must document a temporal relationship to vaccination and a medically appropriate assessment to rule out alternative causes. Proposed for telehealth. | Create narrow coding guidance; routine counseling or an unverified symptom is not enough. | Extra work for a suspected vaccine adverse effect could receive additional payment. |
| Advance care planning - GACP1/GACP2 | New 20-minute clinical-staff ACP codes under direct supervision and incident-to rules. Existing 99497/99498 would report practitioner personal time. The code sets may be reported together if each time threshold is met. Proposed for telehealth. | Build consent, time, supervision, prior-service and documentation controls. | Staff time and clinician time would be separated more clearly. |
| Behavioral health / APCM / CCM | CMS proposes higher work RVUs for CoCM codes 99492-99494, G2214 and APCM behavioral-health add-ons G0568/G0569, plus a higher behavioral-health care-manager labor rate. CMS does not propose a core redesign of APCM base codes or CCM service requirements. | Positive opportunity for integrated behavioral health; do not rebuild APCM or CCM because of this draft. | Behavioral integration pays better; most existing care-management rules stay put. |
| Shared-TIN controls | The proposal uses same physician/same group rules, TIN/NPI QP status and TIN-level quality requirements. In a shared group TIN, claims from separate clinicians or practices may create enterprise effects, and a TIN-level quality exclusion may not isolate one specialty office. | Centralize test claims, education, exceptions and MAC questions across the group before operational changes. | One local coding decision can affect the whole group. |
04 MSSP financial terms
CMS proposes stronger participation tools and benchmark protections, but BASIC Level E versus ENHANCED remains a local modeling decision.
| Policy | Direction | What CMS proposes | Practical interpretation |
|---|---|---|---|
| BASIC Track Level E | POSITIVE | For agreement periods beginning January 1, 2027 or later, the maximum shared-savings rate would rise from 50% to 60%. Existing agreement periods are not changed. CMS also anticipates a time-limited post-final-rule window for eligible January 1, 2027 applicants to change their BASIC-versus-ENHANCED selection in either direction. | Level E becomes more competitive while ENHANCED retains a 75% maximum rate. Simplified: Level E gets more upside without adding ENHANCED-level downside. |
| ENHANCED positive regional adjustment | POSSIBLE NEGATIVE | For lower-spending ENHANCED ACOs entering agreement periods in 2027 or later, the maximum positive regional-adjustment weight would fall from 50% to 35%. Higher-spending and BASIC weights are unchanged. CMS states this could lead some ACOs to choose BASIC Level E instead. | Potential benchmark headwind for an ACO that remains lower cost than its region. Simplified: ENHANCED may lose some benchmark credit, making Level E relatively more attractive. |
| Prior savings adjustment | POSITIVE | For eligible agreement periods beginning in 2027 or later, the prior-savings scaling factor would rise from 50% to 75%. | CMS would preserve more of the savings an ACO already created, subject to eligibility and the cap. Simplified: CMS remembers more of the savings already produced. |
| Risk-adjusted 5% upward-adjustment cap | MIXED | CMS would calculate the existing 5% upward-adjustment cap using risk-adjusted national per-capita expenditures, affecting positive benchmark adjustments including prior savings and growth. | The cap dollar amount can rise or fall with enrollment-type risk; this is not a cap on risk-score growth. Simplified: It limits selected benchmark increases, not the ACO risk score itself. |
| Growth adjustment | POSITIVE IF ELIGIBLE | A new adjustment could reward growth involving newly recruited clinicians inexperienced with specified shared-savings initiatives and beneficiaries new to value-based care, subject to detailed tests and the overall cap. | Strategic growth may help; ordinary roster movement does not automatically qualify. |
| ACPT forecast and guardrails | POSITIVE / MIXED | CMS would replace the fixed five-year projection schedule with performance-year-specific forecasts. New 2027+ cohorts receive a -1.0 / +1.5 percentage-point guardrail versus observed national growth; specified older cohorts receive lower-bound protection. | Less projection-error risk, but less five-year predictability. Simplified: CMS puts bumpers around its forecast so a major miss is less likely to sink the benchmark. |
| PY 2025 reconciliation / shared-savings timing | DELAYED; LIKELY FAVORABLE | Because the ACPT lower-bound guardrail would apply retroactively to PY 2025, CMS would hold reconciliation until the final rule. CMS expects financial results in November 2026 and shared-savings payments in December 2026. Affected ACOs would benefit from the recalculation or be unaffected. | Plan cash timing for December, not early fall. Simplified: the payment comes later, but should be the same size or larger. |
| MOD2 longitudinal-care economics | OPPORTUNITY WITH ACCOUNTABILITY | The proposed 32% modifier pays qualifying longitudinal E/M work across eligible specialties. Allowed charges count in assignment and ACO expenditures. | Model fee-for-service revenue, attribution, quality and downstream utilization together. Simplified: an ACO may receive more visit revenue, but the payment also counts as ACO spending. |
| Part B cost-sharing support | NEW OPPORTUNITY; GOVERNANCE NEEDED | A CMS-approved ACO could reduce or eliminate selected Part B deductible and/or coinsurance for eligible assignable beneficiaries and selected services, targeted as early as April 1, 2027. Drugs and DMEPOS are excluded. Participating practices enter voluntary written arrangements and the ACO reimburses waived amounts. | Potential access/engagement tool, but requires an application, clinical goals, beneficiary eligibility, records, monitoring and budget limits. |
05 Quality, assignment, and QP status
Near-term flexibility increases. The implementation path still has to be technically reliable, auditable, and clear for multi-TIN clinicians.
| Topic | Direction | What CMS proposes | Practical interpretation |
|---|---|---|---|
| Quality Reporting: APP Plus Measure Set | POSITIVE | PY 2027 and subsequent years would use eight total measures: five ACO-reported clinical measures, two CMS-calculated administrative claims measures and CAHPS. Planned Q305 and Q493 additions would be removed. | Fewer measures, but all five clinical measures still require reliable data. |
| Medicare eCQM | EVALUATE LOCALLY | New optional end-to-end electronic collection type using assigned beneficiaries, 75% data completeness and flat benchmarks. ACOs may mix collection types by measure. Medicare eCQMs do not qualify for the eCQM/MIPS CQM reporting incentive or Complex Organization Adjustment. | Potentially attractive denominator, but validate patient matching, identifiers, CEHRT extraction, submission and audit evidence. |
| PI/CEHRT gets easier | POSITIVE | For PY 2027+, the ACO would meet the MSSP CEHRT requirement by doing at least one of three activities: fully report one eCQM/Medicare eCQM using CEHRT; attest that certified FHIR capability supported complete reporting of a measure; or attest to one of three ACO metrics (e-prescribing, bidirectional HIE or provider-to-patient exchange). | Meaningful burden relief. Clinicians independently subject to MIPS keep applicable MIPS PI duties. |
| SAFER Guide / Security Risk Analysis | CLARIFICATION | For MIPS PI, the High Priority Practices SAFER Guide remains required and unscored. CMS proposes removing the Security Risk Analysis measure/attestation beginning PY 2027, while expressly stating that underlying HIPAA security risk analysis and management requirements continue. | The reporting checkbox changes; the underlying security work does not disappear. |
| Measure-specific TIN exclusions | POSSIBLY LIMITED | Beginning with PY 2026, an ACO could exclude a participant TIN for specified circumstances, including specialty CEHRT that cannot support the measure, only if remaining TINs represent at least 95% of assigned beneficiaries before measure logic and 75% completeness is then met. | In a shared TIN, an individual specialty-practice exception may be difficult to use. |
| Digital quality direction | FUTURE / RFI | CMS describes an anticipated 2028-2029 FHIR transition and a 2030 mandatory direction, but repeatedly states that benchmarking, reporting options and adoption require future notice-and-comment rulemaking. | Treat 2030 as strategic direction, not a finalized requirement in this rule. |
| Assignment changes - PY 2027 | MIXED | CMS proposes adding G2011, G0396, G0397, GADV1 and GACP1/GACP2 to primary-care services used for assignment. Allowed charges for underlying E/M services billed with MOD1/MOD2 also count. | Update assignment code maps if finalized. |
| Assignment changes - PY 2028 | MIXED | Specified primary-care charges billed by an ACO professional through a nonparticipant TIN would stop competing in plurality assignment, though expenditures still count. Month-level eligibility would bring some MA-to-Original Medicare switchers into assignment sooner. | Can reduce some attribution leakage but may add higher-cost lives. |
| Quality gate | STILL MATERIAL | The smaller measure set does not remove the quality performance standard or the consequences of reporting/scoring failure for shared savings and losses. | Fewer measures does not mean quality matters less. |
2027 QP outcomes at a glance
| Outcome | Threshold | Operational result | Simplified |
|---|---|---|---|
| Full QP | At least 75% of payment amounts OR 50% of patients | QP treatment applies at the ACO-affiliated TIN/NPI; the clinician avoids MIPS there and receives the applicable higher QP conversion-factor update. | Full QP credit |
| Partial QP | At least 50% of payment amounts OR 35% of patients, but below full QP | The clinician may elect not to report MIPS, but does not receive the full QP payment benefits. | Middle lane |
| Below Partial QP | Below 50% of payment amounts AND below 35% of patients | MIPS applies unless the clinician qualifies for a different exclusion. | Back in MIPS |
06 Ambulatory Specialty Model
ASM begins in 2027 because it was finalized previously. This rule proposes refinements rather than creating the model.
| ASM item | What it means |
|---|---|
| What ASM is | A mandatory 2027-2031 model for selected TIN/NPI physicians in selected geographies who meet condition-specific volume criteria. Heart failure: cardiology. Low back pain: anesthesiology, interventional pain, neurosurgery, orthopedic surgery, pain management and PM&R. |
| Financial mechanics | Performance in 2027 affects payment in 2029. The payment multiplier applies to all covered Medicare Part B professional services, not only condition-related claims. The range is +/-9% in the first two payment years and increases to +/-12% in the final payment year. |
| What this rule proposes | Refinements to TIN-change and exception rules; specialty redesignation; quality measures, benchmarking and scoring; individual/group improvement-activity submission; PI alignment and suppression; possible PRO and rural points; reports, waivers and collaborative care arrangements. |
| Practical interpretation | Obtain the separate official geography and participant information, map potential NPIs/TINs, and keep ASM compensation and MSSP economics separate until local exposure is known. |
07 Advocacy priorities and CMS signals
Stakeholder positions identify risk and emphasis. They do not establish CMS policy.
| Rank | Multispecialty issue | Organizations emphasizing | Stated direction | Practical read |
|---|---|---|---|---|
| 1 | Medicare physician payment and MEI-linked reform | AMGA, AMA, AAFP, TMA, ACP, MGMA, ACS | Broad agreement that annual statutory updates and temporary patches are inadequate; durable inflation-linked reform is favored. | Budget planning and recruitment risk across every specialty. |
| 2 | Modifier 25 same-day E/M and global procedure reduction | AMA, AAFP, AAP, ACOG, ACP, ACS, MGMA, TMA; AMGA | Formal coalition opposition to the 50% reduction; AMGA also identified it as a top member concern. | Highest immediate risk for office-based procedural specialties. |
| 3 | Practice expense methodology and specialty redistribution | AMGA, AMA, MGMA, ACS | Concern about broad redistribution and implementation without adequate specialty-specific validation. | Requires CPT, site-of-service, and specialty modeling. |
| 4 | RPM and RTM staffing, initiating visit, and valuation | AMGA, AMA, MGMA, ACP | Operational concern, especially direct-employment-only clinical staff and payment/coding changes. | Could invalidate outsourced workflows and alter program economics. |
| 5 | G2211 replacement with MOD1 and MOD2 | AMGA, NAACOS, AAFP, ACP, AMA | Generally viewed as a major longitudinal-care payment change; support is strongest for accountable/primary care, with implementation and redistribution concerns. | Potential primary care revenue opportunity and ACO cost/assignment change. |
| 6 | MIPS sunset, MVPs, core measures, PI, and ePA | AMA, AMGA, TMA, MGMA, NAACOS | Support for burden relief is mixed with concern about a mandatory MVP transition and readiness for new reporting requirements. | Requires group-wide reporting strategy before 2029 and ePA readiness for 2028. |
| 7 | QP status at the TIN/NPI and Advanced APM thresholds | AMGA, AMA, NAACOS | Concern that limiting benefits to participating TIN/NPI combinations fragments clinician obligations and weakens entity-level participation. | Multi-TIN physicians may be QPs at the group but MIPS-subject elsewhere. |
| 8 | MSSP benchmark methodology, ACPT, Level E, and ENHANCED | NAACOS, AMGA, AMA, MGMA | NAACOS supports Level E 60% and prior-savings/ACPT protections, but opposes or questions the ENHANCED regional reduction and the 5% cap. | Directly affects 2027 BASIC Level E versus ENHANCED decisions for eligible ACOs. |
| 9 | MSSP quality, APP Plus, Medicare eCQMs, and CEHRT | NAACOS, AMGA, AMA, MGMA | NAACOS calls the quality package a major win; stakeholders favor transition flexibility and lower reporting burden. | Could reduce burden, but only if EHR and registry workflows are reliable and auditable. |
Open the full advocacy stance report
CMS strategic signals
| # | Signal | Confidence | Official evidence in this rule | What it signals |
|---|---|---|---|---|
| 1 | Payment is being redirected toward longitudinal accountable care | HIGH | MOD2 pays 32% for eligible ACO/LEAD longitudinal visits; Level E rises to 60%; CMS asks about prospective primary care payment. | Strategy is not simply a primary care increase. CMS is making accountable relationships more financially distinct. |
| 2 | CMS is more willing to impose broad overlap and integrity edits | HIGH | Modifier 25/global reduction, remote-monitoring staffing rules, global-package data questions, and duplicate-testing RFIs. | Procedural and vendor-supported services face greater scrutiny and should be supported with local evidence. |
| 3 | Practice expense is moving away from specialty survey-based allocation | HIGH | The IPCI is phased out and code-level allocators replace specialty-level rescaling. | Specialty economics will shift even when work RVUs do not. |
| 4 | ACO quality is being narrowed toward assigned patients while digital reporting remains the destination | HIGH | Medicare eCQMs, flat benchmarks, TIN exclusions, continued MIPS CQMs, CEHRT alternatives, and FHIR transition RFI. | CMS is reducing immediate burden without abandoning digital quality. |
| 5 | CMS is tightening the link between APM participation and payment benefits | HIGH | QP and Partial QP benefits would attach to participating TIN/NPI combinations. | Roster accuracy and outside billing relationships become strategic. |
| 6 | Specialist accountability is expanding | HIGH | ASM launches in 2027 and CMS asks how to integrate specialists into MSSP. | Specialty strategy must address both mandatory models and ACO participation. |
| 7 | CMS is balancing ACO growth against selection and benchmark gaming concerns | MEDIUM-HIGH | Level E incentives, ENHANCED regional reduction, prior savings, risk-adjusted cap, growth adjustment, and assignment changes. | ACOs should model the package as one system, not as isolated favorable or unfavorable provisions. |
Protect office-based specialist economics, preserve legitimate longitudinal-care revenue, test the new ACO quality pathways, and treat CMS's accountable-care incentives as an opportunity only after the financial and operational math is complete.