A4H thanks lawmakers for showing strong support for the continued development and expansion of innovative payment models
Washington, D.C. (July 24, 2025) –Accountable for Health, a nonpartisan national advocacy and policy analysis organization working to accelerate the adoption of effective accountable care, released the below statement in response to the 2026 Proposed Medicare Physician Fee Schedule. The rule, released on Monday July 14 by the Centers for Medicare and Medicaid Services (CMS), proposed several changes to physician payment and the Medicare Shared Savings Program, Medicare’s largest accountable care model. Facts sheets on the proposed rule are available online.
“Overall, Accountable for Health thinks there are a lot of good things to better outcomes, improve care experiences, increase access and lower costs in the proposed rule.
“On the skin substitute issue, CMS is changing the reimbursement from $3,660/square centimeter to about $125/square centimeter. That alone will be enormously helpful to accountable care organizations (ACOs) and will address wasteful spending in Medicare. However, ACOs are still financially responsible for the outrageous billing practices around skin substitutes before this change would start in 2026. We still need a better fix for that historical spend.
“Rooting out waste, fraud, and abuse is an overlooked benefit of accountable care, and spotting these sorts of practices should be commended and a reason to further support providers practicing in these models.
“We also for the first time see a higher payment update for Advanced Alternative Payment Model (APM) clinicians via the conversion factor. That higher update provides greater incentive to participate in these valuable APMs. We continue to press Congress to provide even greater incentives to encourage more providers to adopt APMs.
“Other laudable proposals include granting more flexibility for ACOs on the beneficiary threshold, which can be a barrier to participation for smaller ACOs; giving five years of upside only participation before moving to two-sided risk, a win since we know risk-based performance drives results; and allowing for ACO changes mid-year for ownership changes, which will allow new entities with no Medicare billing history a chance to participate.
“Accountable care improves patient experiences of care and health outcomes while lowering costs. For nearly two decades, accountable care has delivered on the promise of reducing fragmentation, identifying and eliminating waste in the healthcare system, and connecting with people to improve their overall health.
“Overall, it’s clear that the Trump administration is committed to growing accountable care and wants to create more opportunities for providers to participate in ACOs.”
Contact:
Mara McDermott, CEO of Accountable for Health
mmcdermott@accountableforhealth.org
About Accountable for Health
Accountable for Health (A4H) is a 501(c)(4) national advocacy and policy analysis organization accelerating the adoption of sustainable, effective accountable care that improves health care quality and outcomes and lower costs. We represent a broad, diverse group of accountable care stakeholders working to improve the way health care is delivered to people across the county, across various payers, programs, and delivery models. A4H provides advocacy, research, and education to improve outcomes and patient experiences while lowering costs.
For more information, visit https://accountableforhealth.org/. Follow us on LinkedIn and Twitter (@acct4health). ###
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Accountable for Health supports the introduction of the bipartisan Patients First Act and looks forward to working with the bill's sponsors to strengthen these proposals and ensure they maximize physician participation in accountable care and improve quality while lowering costs for Medicare beneficiaries.
Accountable for Health is encouraged that CMS’s 2027 Physician Fee Schedule proposed rule recognizes the central role primary care must play in building a stronger, more sustainable Medicare program.
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