Plus, our thoughts on CMS's PY24/25 ACPT adjustments.

On July 14, CMS released its proposed CY27 Physician Fee Schedule, and separately announced updates to the ACPT benchmark factors for 2024 and 2025 start-year ACOs today. The news is good for ACOs on both fronts.  

Here, we unpack the most vital need-to-knows. 

The Big Headlines

ACO clinicians get paid more for the same visits: CMS would fold the G2211 add-on into a modifier on every E/M level — a 16% bump for non-ACO clinicians, 32% for MSSP or LEAD ACOs. It's voluntary, billable for all patients (not just attributed ones), and the first time the fee schedule has paid ACOs a premium for the same service.  

Established ACOs get retroactive relief (a guardrail proposed in the rule, distinct from the calculation-error fix below): If CMS's ACPT projections ran more than 1% below actual national spending growth, benchmarks get corrected upward for ACOs that started in 2024-2026 — this can only help, never hurt. The tradeoff: PY 2025 reconciliation moves to November and payment to December, so CMS has time to build the fix in. 

Benchmark and track economics get a net-positive refresh: More generous shared savings splits across Basic Level E are a positive development, but some ENHANCED ACOs may see savings compress slightly under the new regional adjustment weights. CMS's own modeling shows the changes are net positive overall (more in the deep dive below). 

The conversion factor retreats: $33.17 for qualifying APM participants, down 1.19%, and $32.84 for everyone else, down 1.68% — a one-year congressional boost expiring, not a new CMS cut.  

Beneficiary notifications get simpler: Instead of a notice tied to each patient's first visit, ACOs would send one standardized mailing by May 30. The 180-day follow-up requirement disappears entirely.  

Lastly, CMS is correcting an ACPT error and reopening 2024 settlements (already final, separate from the proposed fee schedule.  

The Technical Deep Dive

MSSP: Benchmarks and Financial Methodology 

2027+ agreement periods: ACPT moves to annual projections with tighter guardrails (1 point below or 1.5 points above national growth). The prior savings adjustment factor rises from 50% to 75%, softening rebasing impacts. The 5%-of-USPCC benchmark cap becomes risk-adjusted for acuity instead of a flat dollar cap. A new growth adjustment rewards recruiting providers and beneficiaries new to value-based care. 

Track economics: For agreement periods starting in 2027, BASIC Level E sharing rises from 50% to 60%, while the ENHANCED's regional adjustment weight drops from 50% to 35% for efficient ACOs. While this could compress savings for historically efficient ACOs, CMS's modeling shows the combined effect, paired with the prior savings adjustment increase, is net positive.  

MA-like beneficiary benefits: With CMS approval, ACOs could reduce or eliminate Part B cost sharing, targeted for April 1, 2027. 

Quality reporting updates: A new Medicare eCQM option lets ACOs report on assigned beneficiaries only, but requires the 40th percentile score for maximum sharing, which is a higher bar than all-payer MIPS eCQM's 10th/40th thresholds. Starting PY26, ACOs can exclude certain TINs if 95% of beneficiaries stay covered. Promoting Interoperability sunsets as a requirement in PY27.  

APP Plus holds at eight measures for PY27 (CAHPS, two claims-based, five ACO-reported), with two planned additions removed, following last year's SDOH screening cut.  

QP status gets easier: the CAA, 2026 restores 2026 thresholds and sets a 3.1% incentive for 2028. QP status would move to the TIN/NPI level, tying benefits to your ACO TIN.  

Beneficiary notifications simplify: The standardized written notice moves from a first-visit trigger to one fixed mailing by May 30. The 180-day follow-up communication and its record-retention requirement go away entirely; Notice content, in-facility signage, and on-request written notices stay the same.  

CMS updating ACPT factors for 2024 and 2025 start ACOs (already final, separate from the proposed fee schedule): CMS identified an error in the ACPT calculation for 2024 and 2025 start ACOs and is updating the factors for both. CMS is reopening the 2024 settlement, which can only benefit ACOs — nothing negative.  

LEAD: What's Changed and What Hasn't

Professional Risk Option's savings rate rises to 60% (loss stays 50%) for PY27, regardless of MSSP's parallel proposal, with a re-election window before launch. Participant providers can bill the 32% modifier; LEAD instead adds a 1.5% fee for higher-spending ACOs (no growth adjustment).  

As of this publishing, CMMI still hasn't released LEAD's complete technical specifications (including the new HCC models and coefficients). 

Other Payment Changes to Know

Behavioral health wins big: Psychologists and social workers gain 11-12%, while procedural specialties lose ground — including a 50% cut to same-day E/M visits billed with global procedures.  

Remote monitoring tightens in 2027: RPM/RTM needs an initiating visit, RTM is limited to established patients, and only practice staff can bill. Telehealth flexibilities continue through 2027, including the mental health in-person waiver and RHC/FQHC billing.  

340B reporting goes mandatory, no revenue impact: Entities submit Part D claims data to CMS starting 2027, so CMS can exclude 340B-discounted units from manufacturer rebate math. Nothing changes in what you're paid.  

RHC and FQHC updates: Diabetes self-management training and medical nutrition therapy become stand-alone billable visits paid at the all-inclusive rate under the RHC benefit, a meaningful access win for rural chronic disease care.  

Medicare eligibility: CMS proposes new limits for certain noncitizens.  

Looming Deadlines

PFS comments are due September 14. We’re working with our ACO partners and advocacy groups to respond, with final rules expected to be published sometime in November. PY25 results and payments to follow.