The CY 2026 Physician Fee Schedule Proposed Rule introduces major changes for ACOs, including accelerated risk progression, revised quality metrics, and new beneficiary requirements. Learn how these updates impact your financial strategy and operational workflows—and how to prepare before the September 12 comment deadline.

The 2026 CMS proposed rule introduces major updates for ACOs in the Medicare Shared Savings Program (MSSP), including mandatory APP reporting, a stronger push toward digital quality measures, and higher performance thresholds. Key changes also include revised benchmarking, beneficiary attribution adjustments, and expanded Promoting Interoperability requirements. ACO leaders should prepare for increased digital reporting demands while taking advantage of new flexibilities—especially for rural and smaller ACOs. Stay informed and ready for compliance ahead of the final rule.

Protect Your MSSP Benchmark: The 90-Day Secret to Accurate Risk Capture

Your MSSP benchmark hinges on one critical rule: chronic conditions must be flagged, documented, and closed every 90 days. Missed diagnoses = an underweighted benchmark, leaving your ACO financially exposed.

Here’s the fix:

1. Flag suspected conditions quarterly (meds, labs, care gaps).

2. Document HCCs during visits—specificity is key.

3. Close the loop: confirm, rule out, or refer.

Skip the cycle? Risk scores regress, costs spike, and audits loom. Compliance isn’t year-end—it’s every 90 days.

Start today:

• Build a suspect condition registry.

• Train providers on HCC validation.

• Audit charts monthly, not annually.