In July, CMS proposed a strong push toward accountable care in the CY2027 Physician Fee Schedule proposed rule. CMS itself called the rule "transformational." None of it is final yet, and CMS usually releases the final rule in early November.
Here is what the rule proposes for the Medicare Shared Savings Program.
The headline: a proposed 32% E/M modifier
The biggest item is a proposed new modifier that clinicians in a Medicare Shared Savings Program ACO or the new LEAD Model could choose to add to E/M visits. CMS proposes that it would increase payment for the associated E/M visit by 32%. It would not be limited to the patients assigned to the ACO, so it could apply to E/M visits for any Medicare patient the clinician sees. The modifier is still a proposal and could change in the final rule.
More reasons CMS gives to join
- The shared savings rate for Level E of the BASIC track would rise from 50% to 60%.
- A new benchmark growth adjustment would reward ACOs for bringing in clinicians and patients who are new to value-based care.
- Beneficiary assignment would add new primary care service codes starting with the 2027 performance year.
- Traditional MIPS reporting would end in 2029, with clinicians moving to MIPS Value Pathways (MVPs) unless they are in a MIPS APM and report the APM Performance Pathway.
Taken together, these proposals would make joining an ACO more attractive than it has been in years, if CMS finalizes them.
The barrier was never the incentive
The incentive was never what held most practices back. The barrier is the infrastructure: proving your quality performance, managing chronic patients between visits, closing care gaps, and having the data ready to report. Most independent practices would happily capture these dollars. They just are not set up to do the operational work that accountable care requires.
That gap, between the incentive and the infrastructure, is where practices win or lose in value-based care.
Timing
The window to join an ACO for the 2027 performance year has already closed. ACOs submit their participant lists to CMS months before the year starts. If accountable care is on your radar, talk to ACOs now about the 2028 performance year.
What to do now
- If you are ACO-curious, look at how the proposed 32% E/M modifier would apply to your Medicare visits, keeping in mind it is not final.
- Get your quality and chronic-care performance documented now, so you are ready when the next application window opens.
- Watch for the final rule. The comment period closed September 14, 2026.
How SmartOps Health helps
This is the infrastructure gap SmartOps Health was built to close. We surface the care gaps and value-based dollars across every payer, help close them with outreach and follow-through, and track the performance that accountable care rewards, without your practice adding headcount.
Want to see where your practice stands going into 2027? Get a free gap scan.