On Tuesday, the Centers for Medicare & Medicaid Services (CMS) proposed shifts to Medicare’s Shared Savings Program (MSSP), accountable care organizations (ACOs) and physician payment structure with the broad goal of propelling a shift toward value-based care.
The proposed changes, which include allowing ACOs with approved applications to decrease or cut beneficiary out-of-pocket costs for select items and services, physician fee schedule redesigns and sunsetting traditional Merit-based Incentive Payment System (MIPS) reporting in 2029, could reshape how home-based care agencies partner with ACOs ahead of the expected final rule later in 2026.
“I would say it’s a recalibration of the program rather than an incremental or genuine shift,” Brian Fuller, managing director at ATI Advisory’s Provider Strategy and Care Transformation Practice, told Home Health Care News.
The CMS proposal aims to shift from “sick care” to value-based care by implementing reforms to Medicare’s physician payment and expanding accountable care, according to the proposal.
To transition toward value-based care, the proposal seeks to make Medicare ACOs easier to join and more rewarding, while moving clinicians away from MIPS reporting and toward specialty-focused MIPS Value Pathways (MVPs).
The proposal gives ACOs a lever to reduce or eliminate beneficiary cost sharing for Part B items and services, Fuller said, which is important to home-based primary care and home-based care overall. “It can be a utilization barrier for the population that home-based care providers serve — particularly those that are frail, complex, or dually eligible, where cost sharing has historically been a barrier for either utilization at all or for sticking with your full plan of care start to finish,” Fuller said.
Fuller said that CMS’ proposal includes a cost containment risk for home-based care providers, which poses some risk for home health providers, but is more likely to impact other healthcare industries.
“When it becomes more difficult for ACOs to generate savings, wherever that may come from, post-acute and home-based services are often subject to tighter utilization management because that is the easiest lever to pull,” Fuller said. “That, often, is less restrictive towards home health utilization and more towards skilled nursing facility utilization, but I would say it’s somewhat of a tangential or indirect risk.”
Changes to MIPS and physician fee schedule
CMS’ proposal also alters the physician fee schedule to reflect modern medical practice. It would revise “accumulated layers of outdated payment policies and billing conventions.” Instead, CMS would seek to align payments with the resources required for delivered care, account for efficiencies when multiple services are performed in one patient encounter, augment billing practice oversight and increase physician pay rate calculation transparency, according to the CMS.
Beyond changing the physician fee schedule, the CMS proposal also sunsets traditional MIPS reporting in 2029. The initial purpose of MIPS was to transition Medicare from a fee-for-service system toward a more value-based one. Moving forward, the CMS would establish specialty-focused MIPS Value Pathways (MVPs) as the main MIPS reporting option. The agency states that three new proposed MVPs center on diabetes, hypertension and hospital-based care to incentivize prevention.
Although CMS’ proposal is already notable, Fuller added that requests for information (RFIs) could reshape the final rule further.
“I would say generally what we have proposed as separate from the RFI is certainly greater than incremental tweaks, but it could be fairly monumental if they do move forward with some of the features that they are asking questions about in the RFI — which is a strong signal that they’re considering those things,” Fuller said.
While the proposal can certainly change throughout the coming months, Fuller said home-based care providers can still be proactive with ACO and primary care physician partnerships. Fuller suggested providers begin strategizing internally and initiating “soft outreach” to ACO and primary care physician partners in their markets.
Home-based care providers might also consider submitting a comment letter by the Sept. 14, 2026 deadline, Fuller added.
“I would be leveraging this new Part B cost-sharing proposal as the catalyst to have a different conversation. I would also be formulating a strategy around helping an ACO figure out how they could use that to their advantage, what the return on investment would be for them structurally if they were to use that, and why you, as a provider in their market, are the preferred provider that they should be partnering with,” Fuller said. “I would be working on that now.”