Medicare payment policy shapes what your practice can invest in patient care, how much time your team spends reporting data, and whether better care translates into financial rewards. In our comments on the proposed 2027 Physician Fee Schedule, Vytalize asked CMS to strengthen payment for accountable care, reduce unnecessary reporting, and protect the shared savings that help practices reinvest. These priorities reflect the work we do alongside our physician partners
The payment and reporting proposals discussed below are “proposed,” and CMS is expected to issue the final rule this fall with varying effective dates. On some of the longer-term payment ideas, CMS requested more information from commentors, without making a formal proposal. Our comments on these are designed to inform CMS’s future direction.
Physician Payment Pressures Persist, but CMS Strengthens Support for Accountable Care
For physician payment, the conversion factor that sets base payment rate will fall by 1.19% for “qualified providers” (including most Vytalize ACO participants) and 1.68% for other providers, unless Congress acts to adjust a legal requirement. Vytalize’s letter emphasized our advocacy for a positive update to physician pay and more stable physician payment long-term.
CMS proposes additional payment for qualifying evaluation and management visits furnished by eligible practitioners in Medicare Shared Savings Program (MSSP) and LEAD accountable care organizations (ACOs). We support this recognition of the work required to coordinate care and take responsibility for quality and total cost.
The proposed ACO modifier, called MOD2, would add 32% to the base visit payment for the complex care management required from an ongoing longitudinal care relationship, only for participant providers in a Medicare ACO program. This is double the 16% base visit increase for the MOD1 code, available to providers who do not participate in an ACO. Vytalize supports this change as a much-needed recognition of the work of accountable care, but asked CMS to ensure that implementation of MOD2 does not negatively impact shared savings calculation. We also requested that CMS extend the benefit to Rural Health Clinics and Federally Qualified Health Centers to recognize the essential role they play in value-based care.
Improvements to Quality Reporting
Under the current Medicare clinical quality measure (CQM) definition, the reporting population includes beneficiaries within a practice who are not assigned to the ACO. In Vytalize’s latest Medicare CQM list, almost 20% of beneficiaries fell into that category.
CMS proposes aligning this reporting population with assigned beneficiaries beginning in 2027, and we asked CMS to make that change available for the 2026 performance year, since those data will be submitted in 2027. For affected practices, this could reduce the patient records needed for reporting this cycle. Better alignment would help reduce administrative burden in the quality reporting work that practices and Vytalize take on together and ensure that quality reports properly reflect ACO results.
Vytalize also requested more transition time for certified electronic health record requirements and continued small-practice exclusions, so the many independent practices we serve have more time to prepare for electronic reporting with Vytalize’s assistance.
Timely Funding and Protection of Earned Shared Savings
CMS has announced that reconciliation for the 2025 performance year will be delayed until November 2026 while it finalizes corrections to its spending-growth methodology that would raise shared savings for affected ACOs. We support the proposed change, but asked CMS to issue provisional payments using the existing methodology as soon as possible, followed by supplemental payments when the correction is made. Earlier CMS payments would help Vytalize distribute shared savings to our aligned practices faster.
We also opposed reducing a benchmark adjustment that benefits regionally efficient ENHANCED-track ACOs, and urged CMS to adopt measures allowing ACOs and their practices to keep more of the savings that they demonstrate over time. We supported CMS’s proposal to incentivize ACO growth and advocated for clearer policies to prevent improper payments from distorting ACO financial results. These technical policies affect the resources available to support patient care and reward practice performance.
Technology That Strengthens Clinical Decision-Making
As CMS asked for information to explore payment for technology-enabled primary care, we are advocating for tools that strengthen the physician-patient relationship and demonstrate value through better outcomes and lower total cost of care.
Vytal Insights™, our clinical decision support platform, illustrates this approach. It presents patient-specific recommendations and supporting evidence within the practice’s electronic health record, leaving decisions with the treating clinician. In a 2024 randomized pilot, clinicians receiving recommendations acted on them at 1.9 times the rate of the control group. The pilot measured uptake of clinical recommendations, illustrating how support within existing workflows can influence care delivery.
Our position is that payment should support useful innovation while preserving accountability for results. Within an ACO, technology can be selected and supported alongside care coordination, analytics, and clinical services, with the ACO retaining responsibility for overall quality and cost.
Funding the Next Generation of Accountable Care
Value-based care transformation requires investment before shared savings arrive. Vytalize helps bridge that gap through shared savings advances and shared clinical and operational resources. CMS is seeking input on options, such as prospective primary care payment in MSSP, to distribute advance funding to ACOs. Vytalize supports prospective funding options for MSSP, which would help us to invest in technology and care services that generate savings, and expand our program of advancing shared savings to our partner practices.
What Happens Next
We will review the final rule and explain what the adopted changes mean for our partner practices, including relevant timing and implementation steps. If you have questions about your practice’s participation or payment arrangements, contact your Vytalize representative.
Sources
Vytalize Health comments on CMS-1848-P, September 14, 2026.
CMS 2027 Physician Fee Schedule proposed rule fact sheet
CMS 2027 Medicare Shared Savings Program proposals fact sheet
