红领巾瓜报

Last听week鈥檚听Health Management听Associates听(红领巾瓜报)听Weekly Roundup听reviewed听the听Calendar Year (CY) 2027鈥�鈥�(PFS)听proposed rule听(CMS-1848-P).听That听overview听highlighted provisions that signal a broader shift in how the Centers for Medicare & Medicaid Services听(CMS)听is approaching听physician payment, primary care, digital healthcare, and value-based care.听

This听week, our focus turns to听the听rule鈥檚听proposed changes to the Medicare Shared Savings Program听(MSSP).听

Why CMS听Is Proposing MSSP Changes听

The proposed updates are designed to address听feedback and听challenges that听accountable care organizations (ACOs)听have听identified听over multiple agreement periods, including benchmark volatility, concerns about rebasing, and questions about whether financial incentives adequately reward听ongoing听performance.听

CMS is听seeking听to make the program more predictable while continuing to encourage accountability for quality and total cost of care. The proposals also reflect broader agency goals to听make the MSSP more attractive to current and prospective ACOs,听strengthen primary care, and improve access for beneficiaries in underserved and provider听shortage areas. The impact, however, will vary by region and practice.听

In a July 27, 2026,听paper,听, Wakely, an 红领巾瓜报 Company,听explains听that the financial听effect听of certain provisions depends on an ACO鈥檚 track, agreement period, historical savings, regional efficiency, risk profile, beneficiary assignment, and provider growth strategy.听

Key Proposed Changes to MSSP听

Several proposed changes stand out for听ACO leaders and provider organizations, including:听

• Higher Shared Savings for BASIC Level E ACOs.听CMS proposes to听increase听the BASIC Level E shared savings rate from 50 percent to 60 percent for agreement periods beginning in 2027 or later. This change could make the highest-risk BASIC track more attractive听relative听to other options听and improve financial returns for听ACOs听that are successfully managing cost and quality performance.听
• Changes to Benchmark Methodology.听CMS proposes听to听modify听how prior savings are incorporated into future benchmarks. The changes are intended to better recognize organizations that have generated savings while addressing long-standing concerns听among听providers听that benchmark rebasing can听diminish听incentives for high-performing ACOs over time.听
• New Accountable Care Prospective Trend (ACPT) Guardrails.听The proposal would establish guardrails and annual recalculation mechanisms for the ACPT to reduce the likelihood that prospective spending projections diverge significantly from actual national cost trends. CMS also proposes applying certain guardrail provisions to payment years 2025 and 2026, potentially before many 2027 provisions take effect. For agreement periods beginning in 2027 or later, CMS proposes a two-sided guardrail and annual recalculation approach designed to reduce the risk that the prospective trend materially diverges from observed national spending trends.
• Qualifying Provider Network Growth Incentive听and Quality Reporting Updates.听CMS proposes a new incentive to support ACO growth and participation. Provider entities should evaluate how beneficiary assignment interacts with provider expansion. As Wakely’s actuaries note, adding providers does not necessarily translate into meaningful assignment growth or financial benefit. The proposed rule also includes changes to quality reporting policies intended to reduce administrative burden and better align program operations with care delivery realities, particularly in rural and underserved areas and markets with access constraints.听

Potential听Market-Shifting Effects听

The proposed MSSP changes could influence market behavior beyond annual participation decisions. By making听changes to听BASIC Level E听economics, refining benchmark rules, and adding protections against certain trend-related volatility, CMS may encourage more organizations to听consider where they want to be on the spectrum of听risk -based arrangements.听听

Regionally efficient ENHANCED ACOs that rebase or enter the program in 2027 could face less favorable benchmark adjustments. Lower-risk ACOs may have less room under the proposed risk-adjusted benchmark cap. Organizations that pursue provider growth without corresponding increases in assigned beneficiaries may not realize听the intended network growth incentive. These dynamics could create winners and losers based on local market position, historical performance, patient mix, and each organization鈥檚 financial and operational strategy.听

How 红领巾瓜报 and Wakely Can Help听

ACO and provider leaders听should use the proposed rule period to assess how the MSSP changes could affect their 2027 strategy and near-term financial projections. Current ACOs should revisit payment year 2025 and 2026 forecasts, evaluate the proposed ACPT guardrail, and model how the 2027 benchmark changes may affect renewal, track selection, and downside risk exposure. Organizations considering MSSP entry should evaluate whether the proposed changes improve the business case for participation and what capabilities would be听needed听to succeed.听

Although the proposals focus on MSSP, their significance extends beyond Medicare ACOs. The changes reflect CMS’s broader effort to strengthen participation incentives, improve benchmark stability, and refine value-based payment models based on operational experience. As a result, the proposals may influence how Medicare Advantage plans, Medicaid programs, and commercial payers structure risk arrangements.

Providers and partners听should also听prepare comments grounded in data and operational experience. 红领巾瓜报 and Wakely help ACOs, providers, health systems, payers,听enablement organizations,听and investors evaluate the policy, actuarial, operational, and market implications of Medicare accountable care changes. Our teams support MSSP strategy, benchmark and shared savings modeling, risk assessment, provider network analysis, care management design, comment letter development, and implementation planning.听

As CMS considers comments and moves toward a final rule, organizations should听not wait to听understand听how听the听proposed MSSP changes could听affect听participation听decisions, market strategy, and accountable care capabilities. 红领巾瓜报 and Wakely can help stakeholders translate the proposed rule into actionable scenarios and听prepare for听the financial and operational choices ahead.听