On August 9, 2018, the Centers for Medicare & Medicaid Services. (CMS) issued a proposed rule containing a number of important changes designed to strengthen and stabilize the Medicare Shared Savings Program (MSSP). These changes, called “Pathways to Success,” make the MSSP program more attractive than ever for physician-led (non-hospital) Accountable Care Organizations (ACOs).

Recently, Aledade submitted comments to CMS on the proposed changes. On the whole, we believe the ACO program is going to be stronger than ever before. Download the full comment letter and analysis on the new Pathways to Success ACO program.

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Our Policy Expertise

Travis Broome

VP of Health Care Policy

Travis Broome, VP of Health Care Policy, is a veteran of the Centers for Medicare & Medicaid Services. (CMS). Before joining the Aledade team, Travis served as a Regional Director at CMS, overseeing Medicare Part A & B, EHR, and ACO operations across five states. Prior to this, Travis led the team that crafted the early rounds of meaningful use regulations for the EHR Incentive Programs. Travis received a Master of Public Health, and of Business Administration in Health Care Organization and Policy from the University of Alabama at Birmingham. Travis works closely with our CEO and co-founder Dr. Farzad Mostashari and the rest of the Aledade team to ensure that health reform in Medicare, Medicaid and the private sector puts independent, primary care physicians at the center of the transition to value-based payment. Travis has published and presented extensively on value-based payment models, with his work featured by the American Journal of Managed Care (AJMC), the Health Information and Management Systems Society (HIMSS), the American College of Physicians (ACP), the National Association of ACOs (NAACOs), and the Centers for Disease Control and Prevention (CDC), among others.

Understanding What Risk Means for Your Practice


The proposed rule improves risk across these categories, and makes it more appealing for independent practices, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to access and succeed in the MSSP. Aledade advocated for many of these policy changes, including:

  • Improved benchmarking methodology that properly accounts for regional variations in costs
  • A new risk score methodology that more accurately reflects the cost profile of beneficiaries attributed to ACOs
  • New participation tracks that make it possible to pursue more savings opportunities sooner, based on an ACO’s
    experience with risk
  • Downside risk protection that limits any losses to a defined percentage of Medicare revenue
  • Greater participation flexibility that allows ACOs to select from two beneficiary attribution methodologies, move
    freely between participation tracks, and select their preferred level of revenue risk

What’s Next?

Once the rule is finalized, independent practices, FQHCs and RHCs can look forward to a more stable and even playing field for MSSP ACOs.

The additional flexibilities afforded by the proposed rule represent exciting new opportunities for physician-led ACOs, making it even more important for them to work with a partner capable of properly assessing their options and supporting them throughout their value-based care journey.