A4H Scores Major Win on Skin Substitutes Payment Policy in Final Medicare PFS Final Rule. CMS finalized its commonsense proposal to curb fraud, waste, and abuse in the use of skin substitutes under Medicare in the 2026 Medicare Physician Fee Schedule (PFS) Final Rule. A4H made it a top priority to have CMS finalize its proposal, including establishing a payment rate of $127 per square centimeter. As this “Year of Action” graphic illustrates, A4H organized more than 50 meetings with congressional and administrative offices, secured media placements, and launched an educational advertising campaign in support of this important issue. We were more than pleased that CMS finalized this policy.

What’s Next? A4H continues to work on Capitol Hill to build support for the final rule, which is likely to be challenged in court by skin substitute manufacturers. A4H also continues to call upon CMS and CMMI to protect accountable care providers from the effects of skin substitutes fraud and abuse on alternative payment models (APMs) in 2025.

Additional Final Rule Policies Drive Accountable Care Adoption. CMS finalized other changes, which are positive for accountable care providers, including a 3.77 percent reimbursement increase for physicians in qualifying APMs and a 3.26 percent increase for those not in qualifying APMs, and changes to the Medicare Shared Savings Program designed to increase the number of ACOs in the program and drive participation in two-sided risk arrangements. A4H looks forward to continued conversations on Medicare payment policy to encourage engagement with accountable care.

Government Shutdown Ends, Timeline for Healthcare Legislation Unclear. Late on Wednesday, President Trump signed a funding deal to reopen the government through January 30, 2026. While expiring Affordable Care Act (ACA) enhanced premium tax credits were not extended, the funding deal extended key health policies, such as telehealth and Hospital-at-Home, through January 30 and retroactively applied those flexibilities effective October 1, 2025. It remains unclear whether there will be a broader health package at the end of the year or by January 30. A4H continues to work with lawmakers to advance accountable care goals on Capitol Hill and advocate that accountability needs to be built into future payment reform efforts.

A4H Calls on Congress to Enact Long-Term Telehealth Fix in Light of Shutdown Disruptions. A4H joined a broad coalition of healthcare organizations calling on Congress to enact a long-term fix for Medicare telehealth access after the recent expiration of temporary flexibilities. In a letter to congressional leaders, the groups warned that the lapse has disrupted care for more than four million seniors and created financial uncertainty for roughly 30 percent of providers who serve Medicare patients via telehealth. A4H issued a release on this topic following passage of the funding package and will continue to work to advance a long-term solution on Capitol Hill. A long-term solution would contribute to a more stable, predictable environment for accountable care providers.

All 50 States Apply for CMS’s Rural Health Transformation Program. All 50 states applied for the RHT Program, according to CMS. States with approved applications will be eligible for “baseline funding,” or 50 percent of the available funding, distributed evenly among states with approved applications. Approved states will then undergo a “rigorous, data-driven merit review” to compete for the remaining funding. Per the agency, this in-depth review will be led by rural health experts and senior federal review directors. Awards will be announced by December 31, 2025. Several A4H members are pursuing strategies to leverage the RHT Program to build and expand accountable care capabilities in rural communities.

CMMI Announces Medicaid Drug Pricing Model. The GENEROUS (GENErating cost Reductions fOr U.S. Medicaid) Model, is designed to lower drug spending in Medicaid. GENEROUS will be voluntary, begin in January 2026, and run for five years. Participating manufacturers will provide most-favored-nation (MFN) prices based on international prices on certain drugs to participating states, and in return, states will implement standardized coverage criteria. A4H continues to watch for two other drug pricing models currently under review. Historically, CMMI action on drug pricing has drawn increased scrutiny for CMMI from Congress and external stakeholders.

Accountable for Health Institute and West Health Policy Center Convening, Dec 9. Please join us for an in-person event that will bring together industry experts, stakeholders, and government leaders who will take a closer look at ways to strengthen accountable care for an aging population. The convening will be held at the Marriott Marquis in Washington, DC.