All Themes

CMS under the Trump administration is pushing cost-of-care pressure deeper into mandatory and quasi-mandatory payment reform, with CMMI finalizing the GLOBE drug payment model to test most-favored-nation-style Part B pricing while recent CJR results showing roughly $180M in savings strengthen the case for broader episode-based payment expansion ([GLOBE model](https://www.fiercehealthcare.com/payers/cms-finalizes-model-aims-bring-most-favored-nation-pricing-part-b); [CJR savings](https://www.techtarget.com/revcyclemanagement/news/366651340/CJR-Models-180M-savings-pave-way-for-nationwide-expansion)). At the same time, MA is becoming a more contested VBC platform: 2027 Star Ratings put more beneficiaries in bonus-eligible high-rated plans, but MedPAC’s $76B overpayment estimate, benefit pullbacks, and plan exits are intensifying scrutiny over whether MA savings and quality gains are real or financed through coding and rebate dynamics. For ACOs, health systems, and payer strategists, the near-term positioning challenge is to build cost management capabilities that work across drug spend, episodes, chronic specialty care, and MA risk—while preparing for CMS to keep tying affordability to harder-edged payment benchmarks rather than voluntary upside-only models.

Medicare Advantage is entering a more volatile VBC reset: 2027 Star Ratings produced sharp winner/loser dispersion despite surface-level stability, while renewed scrutiny of MA overpayments and CMS proposals around provider-directory scoring and PBM flat-fee limits point to tighter oversight of plan performance, coding economics, and network accountability. At the same time, CMS is expanding model-based cost discipline beyond MA and ACOs—finalizing the GLOBE Part B drug pricing model to test most-favored-nation-style payment constraints and advancing the ACCESS model with wearables/AI partners—signaling a Trump administration push to pair payment pressure with tech-enabled chronic care management and measurable outcomes ([MA star ratings volatility](https://www.healthcaredive.com/news/medicare-advantage-stars-2027-winners-losers/832582/); [GLOBE drug pricing model](https://www.fiercehealthcare.com/payers/cms-finalizes-model-aims-bring-most-favored-nation-pricing-part-b)).

CMS is pushing value-based contracting further into chronic disease and drug-spend management: the ACCESS Model expansion adds heart failure, COPD, substance use disorder, and tobacco-use tracks beginning in 2027, signaling a longer-term CMMI strategy to pair digital care infrastructure with condition-specific accountability for Medicare providers ([HFMA](https://www.hfma.org/payment-reimbursement-and-managed-care/cms-access-model-expansion/)). At the same time, CMS finalized the GLOBE drug pricing model to test most-favored-nation-style pricing for Part B drugs, creating a new cost-control frontier that will affect provider economics, specialty care contracting, and payer-provider risk arrangements ([Fierce Healthcare](https://www.fiercehealthcare.com/payers/cms-finalizes-model-aims-bring-most-favored-nation-pricing-part-b)). The broader environment is becoming less forgiving for Medicare Advantage and risk-bearing entities, with RADV scrutiny, Star Ratings pressure, and MedPAC’s overpayment debate intensifying the tension between coding-driven revenue strategies and demonstrable performance on cost, quality, and population health.

CMS is pushing care coordination deeper into longitudinal chronic-care management: the ACCESS Model expansion adds heart failure, COPD, substance use disorders, and tobacco use treatment tracks effective April 2027, signaling that CMMI under the Trump administration is positioning technology-enabled monitoring, AI, and scalable digital interventions as infrastructure for Medicare VBC rather than standalone pilots ([HFMA](https://www.hfma.org/payment-reimbursement-and-managed-care/cms-access-model-expansion/), [Fierce Healthcare](https://www.fiercehealthcare.com/health-tech/oura-counsel-health-cms-access-model)). At the same time, TEAM’s early implementation is accelerating tighter hospital–outpatient–home health coordination, raising the strategic stakes for ACOs, post-acute networks, and specialty groups that must manage episode leakage, handoffs, and avoidable utilization across settings ([Home Health Care News](https://homehealthcarenews.com/2026/09/9-months-in-team-pushes-outpatient-services-tighter-home-health-coordination/)). The broader direction is a shift from episodic VBC participation toward always-on population management, with Medicaid ACO maternal health work reinforcing the same theme: performance will increasingly depend on data integration, community-based care teams, and accountability for outcomes beyond the clinic visit.

CMS under the Trump administration is pushing Medicare payment policy further into mandatory and tech-enabled value models: CJR’s reported $180M in savings is strengthening the case for broader episode-based expansion, while TEAM is already shifting hospitals toward outpatient joint-replacement pathways and tighter post-acute/home health coordination. At the same time, CMS is expanding chronic-condition value-based infrastructure through ACCESS—adding heart failure, COPD, substance use disorders, and tobacco-related tracks for 2027—signaling that chronic care management, digital tools, and longitudinal risk management are becoming central to Medicare payment strategy ([ACCESS expansion](https://www.hfma.org/payment-reimbursement-and-managed-care/cms-access-model-expansion/)). For payers and ACO-aligned providers, the upside from MA Star Ratings and model participation is being counterbalanced by sharper scrutiny of risk adjustment and coding integrity, including OIG audits and DOJ False Claims Act settlements that reinforce compliance as a strategic constraint on VBC growth ([MA compliance audit](https://oig.hhs.gov/reports/all/2026/medicare-advantage-compliance-audit-of-specific-diagnosis-codes-that-unitedhealthcare-benefits-of-texas-inc-contract-h0609-submitted-to-cms/)).

CMS under the Trump administration is pushing interoperability from compliance infrastructure into VBC operating models: the ACCESS model is adding Oura and Counsel Health to test whether wearables and AI can support chronic-condition management at scale, while CMS-0057-F and the Jan. 1 electronic prior authorization deadline are forcing payers and providers to operationalize APIs, workflow redesign, and real-time authorization—not just publish technical endpoints. For ACOs, MA plans, and Medicaid managed care organizations, the strategic shift is toward tech-enabled population health and outcomes accountability, but the near-term tension is execution risk: data liquidity, audit readiness, documentation integrity, and provider burden will determine whether these tools improve performance or simply create new compliance exposure. See coverage of the [ACCESS model technology additions](https://www.fiercehealthcare.com/health-tech/oura-counsel-health-cms-access-model) and analysis that [CMS-0057-F will test operations, not just APIs](https://www.healthdatamanagement.com/articles/cms-0057-f-will-test-operations-not-just-apis).

Quality measurement is becoming a more direct revenue and model-design lever across Medicare VBC: 2027 Medicare Advantage Star Ratings show over 70% of MA-PD beneficiaries in 4+ star contracts, preserving bonus-payment upside, but higher cut points and reward-factor volatility are raising 2028 revenue risk for plans and provider partners tied to Stars performance. CMS under the Trump administration is also expanding condition-specific accountability through ACCESS, adding heart failure, COPD, substance use disorders, and tobacco-use tracks for 2027, while episode-based models such as CJR/TEAM continue to push hospitals toward tighter outpatient and home health coordination as quality, utilization, and post-acute performance become harder to separate. For ACOs, MA plans, and health systems, the strategic shift is toward metric-driven operating infrastructure—data capture, chronic-care management, post-acute alignment, and measure-specific interventions—rather than treating quality as a compliance function ([ACCESS expansion](https://www.hfma.org/payment-reimbursement-and-managed-care/cms-access-model-expansion/); [2027 MA Star Ratings](https://www.hfma.org/payment-reimbursement-and-managed-care/2027-medicare-advantage-star-ratings/)).

CMS is moving Medicaid quality strategy toward outcomes-based accountability, partnering with 37 states to rethink measures away from compliance checklists and toward whether beneficiaries actually get healthier—an important signal for Medicaid MCOs, ACOs, and providers preparing for tighter alignment between quality reporting, population health performance, and value-based payment incentives ([CMS/state Medicaid quality initiative](https://www.fiercehealthcare.com/regulatory/37-states-partner-cms-initiative-rethink-medicaid-quality-measures)). At the same time, equity-focused Medicaid VBC is facing sharper access and eligibility headwinds: new reconciliation-law provisions, work requirements, and immigrant-eligibility changes could disrupt coverage for high-need groups, while Medicaid ACO experience in Massachusetts shows maternal health initiatives can improve quality when payment models support midwifery, care coordination, and community-based interventions ([Medicaid ACOs and maternal health](https://hooperlundy.com/massachusetts-medicaid-acos-initiatives-improve-maternal-health/)). For VBC stakeholders, the strategic tension is clear: federal and state purchasers are demanding more measurable outcomes and interoperability-enabled operations, but coverage churn and social-risk instability may make attribution, longitudinal care management, and equity performance harder to sustain.

Population health management is shifting from broad care-management rhetoric to operating-model discipline: risk-bearing ACOs are investing in technology enablement, coordinated outreach, analytics, and workflow integration to manage attributed lives more systematically as MSSP scale and savings continue to grow. Under the Trump administration’s CMS, CMMI’s ACCESS Model is also becoming a more visible test bed for tech-enabled chronic care, with expansion into new conditions and participation by wearables/AI players such as Oura and Counsel Health—raising the strategic question of whether digital monitoring can reliably translate into lower total cost of care and better longitudinal management at scale. For ACOs, payers, and health systems, the near-term imperative is aligning specialty, home-based, kidney, and chronic-care interventions into contractable population health infrastructure rather than disconnected point solutions, a tension reflected in new field guidance on ACO technology enablement and VBC operating models ([Duke-Margolis](https://news.google.com/rss/articles/CBMiwwFBVV95cUxPODlCZ0ZNUUQ1QzVyZ2xRMFVRZkVsS3c1UDZzTFhJVVZxS1FPaDBfRkowRHo3SGlTVi02WkFNcWZ5U29qNTJqc0dPNmw0VTZGVElKZlpYQ3FGcXh1djJqWUwxcFh

CMS’s last-30-day activity points to a broader Trump administration push under HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Dr. Mehmet Oz to scale technology-enabled chronic care payment models, with the ACCESS Model expanding to heart failure, COPD, substance use disorders, and tobacco use effective April 2027—signaling growing federal interest in pairing VBC accountability with wearables, AI-enabled monitoring, and condition-specific chronic care infrastructure ([HFMA](https://www.hfma.org/payment-reimbursement-and-managed-care/cms-access-model-expansion/); [Fierce Healthcare](https://www.fiercehealthcare.com/health-tech/oura-counsel-health-cms-access-model)). For Medicaid managed care and Medicaid ACO stakeholders, the strategic read-through is less about ACCESS itself—which is Medicare-focused—and more about the expected spillover: states and MCOs are likely to face pressure to align chronic disease, maternal health, and population-health contracts around measurable outcomes, tech-enabled care management, and tighter attribution/accountability models, while providers weigh whether new digital-care requirements create scalable margin opportunities or additional operational risk.

CMS is pushing primary care VBC toward tech-enabled, longitudinal chronic care as the Trump administration expands the ACCESS Model to include Oura and Counsel Health, testing whether wearables and AI can support scalable monitoring, triage, and engagement outside the clinic ([CMS ACCESS expansion](https://www.aha.org/news/headline/2026-09-16-cms-announces-expansion-access-model)). At the same time, market and state-level pressure is building to rebalance payment toward primary care: Massachusetts is weighing a primary care spending target, California stakeholders are criticizing fee-for-service as structurally misaligned with care transformation, and new Medicare ACO discussions are emphasizing that specialty populations such as kidney disease must be integrated rather than carved out of accountable care. The strategic tension for ACOs, payers, and systems is whether primary care investment, home-based capacity, and AI-enabled monitoring can be financed through durable outcomes-based models—or whether fragmented measures and legacy payment mechanics will dilute the shift toward population health accountability.

CMS finalized the mandatory GLOBE Part B drug payment model, advancing the Trump administration’s most-favored-nation-style strategy to curb Medicare drug spending, though the final rule narrowed scope and savings versus the proposal—reducing near-term disruption but preserving a structural shift toward externally benchmarked specialty-drug reimbursement ([AHA](https://www.aha.org/news/headline/2026-10-01-cms-finalizes-globe-drug-pricing-model), [Fierce Healthcare](https://www.fiercehealthcare.com/payers/cms-finalizes-model-aims-bring-most-favored-nation-pricing-part-b)). The model is already drawing pharma litigation from PhRMA and operational concern from oncology and hospital stakeholders, signaling that VBC organizations, ACOs, and MA plans should expect continued tension between drug-cost containment, provider margin protection, and access management for high-cost infused therapies. In parallel, CMS’s proposed MA directory scoring and PBM flat-fee limits point to a broader pharmacy-management pivot: less tolerance for spread-based incentives and opaque networks, and more pressure on plans to align pharmacy economics with quality, access, and total-cost accountability.

CMS and HHS oversight of Medicare Advantage risk adjustment is intensifying under the Trump administration, with OIG audits and DOJ False Claims Act activity targeting unsupported diagnosis coding and alleged upcoding—most notably audits tied to UnitedHealthcare and Humana overpayments and a [$22.5M Independence Blue Cross settlement](https://www.justice.gov/opa/pr/independence-blue-cross-pay-225m-resolve-false-claims-act-allegations). For VBC stakeholders, the structural shift is from episodic RADV exposure toward scaled, enterprise-wide audit readiness: MA plans, delegated risk groups, and ACO-like provider partners need tighter chart documentation, coding governance, and prospective risk-adjustment controls well before CMS requests records. Meanwhile, litigation over [2027 MA Star Ratings](https://www.healthcaredive.com/news/alignment-lawsuit-2027-medicare-advantage-star-ratings-cms/832774/) and PhRMA’s challenge to the Trump administration’s GLOBE drug-pricing demo underscore a broader compliance environment in which payment model economics are increasingly being contested through audits, quality-score disputes, and courts.

Payment integrity pressure in Medicare Advantage is intensifying as HHS OIG and DOJ actions converge on risk-adjustment coding: recent OIG audits alleged significant overpayments tied to unsupported diagnoses at UnitedHealthcare and Humana plans, while DOJ’s $22.5M False Claims Act settlement with Independence Blue Cross reinforces that MA coding accuracy is now an enforcement priority, not just a compliance issue ([DOJ settlement](https://www.justice.gov/opa/pr/independence-blue-cross-pay-225m-resolve-false-claims-act-allegations); [OIG audit](https://oig.hhs.gov/reports/all/2026/medicare-advantage-compliance-audit-of-specific-diagnosis-codes-that-unitedhealthcare-benefits-of-texas-inc-contract-h0609-submitted-to-cms/)). For VBC organizations, the strategic shift is from retrospective chart defense to always-on documentation, encounter-data governance, and provider education, because scaled RADV scrutiny and public CMS attention to MA operational integrity raise financial risk for payers, delegated risk groups, and ACO-aligned providers that depend on accurate risk capture. CMS’s broader push toward transparency—such as proposed public MA provider directory scores—also signals that payment integrity is being tied to member access, data quality, and administrative accountability, expanding the compliance perimeter beyond coding alone.

CMS’s 2027 Medicare Advantage cycle is signaling a more disciplined, compliance-heavy managed care market: enrollment is concentrating in ≥4-star MA-PD contracts eligible for quality bonuses, while benefit pullbacks, county exits, and reduced plan choice are reshaping network and supplemental-benefit strategy for MA plans and VBC-aligned providers ([HFMA](https://www.hfma.org/payment-reimbursement-and-managed-care/2027-medicare-advantage-star-ratings/), [KFF](https://www.kff.org/medicare/medicare-advantage-plan-availability-varies-widely-by-county-for-2027/)). At the same time, CMS is tightening operational oversight through proposed public scoring of MA provider directories and PBM flat-fee limits, while RADV-related overpayment findings, inaccurate-diagnosis settlements, and renewed Star Ratings litigation underscore mounting risk around coding intensity, data integrity, access accuracy, and quality-measure governance. For ACOs, delegated provider groups, and payers, the strategic imperative is shifting from growth-at-all-costs MA expansion toward defensible risk adjustment, auditable quality performance, narrower but accurate networks, and benefit designs that can withstand tighter federal scrutiny under the Trump administration’s CMS leadership.

CMS and enforcement agencies are tightening the Medicare Advantage risk-adjustment environment, with HHS OIG audits of UnitedHealthcare and Humana plans alleging unsupported diagnosis submissions and DOJ securing a $22.5M False Claims Act settlement with Independence Blue Cross over inflated MA coding—signals that RADV exposure is becoming a core financial and compliance risk, not a periodic audit event ([DOJ settlement](https://www.justice.gov/opa/pr/independence-blue-cross-pay-225m-resolve-false-claims-act-allegations); [OIG MA audit](https://oig.hhs.gov/reports/all/2026/medicare-advantage-compliance-audit-of-specific-diagnosis-codes-that-unitedhealthcare-benefits-of-texas-inc-contract-h0609-submitted-to-cms/)). For ACOs, MA-aligned provider groups, and risk-bearing specialists, the strategic implication is a pivot from retrospective coding maximization toward prospective documentation integrity, chart-level audit readiness, and tighter payer-provider contract terms around encounter data, recoupments, and responsibility for unsupported HCCs. The broader tension is that policymakers and watchdogs are treating MA overpayment estimates—such as MedPAC’s $76B figure—as evidence for structural reform, while plans argue the risk-adjustment rules remain operationally ambiguous, creating uncertainty for VBC organizations whose margins depend on accurate acuity capture.

Medicare Advantage is entering a more volatile VBC operating cycle: 2027 Star Ratings kept a large share of MA-PD beneficiaries in 4+ star contracts, preserving 2028 bonus and rebate advantages for incumbents, but plan-level dispersion and changing cut points are creating material winners and losers in revenue, benefit design capacity, and provider-facing value-based contracts ([HFMA](https://www.hfma.org/payment-reimbursement-and-managed-care/2027-medicare-advantage-star-ratings/); [Wakely](https://www.wakely.com/blog/2027-medicare-advantage-star-ratings-stability-at-the-surface-volatility-underneath/)). At the same time, HHS OIG audits and DOJ False Claims Act activity against MA risk-adjustment practices—spanning UnitedHealthcare, Humana, and Independence Blue Cross—are intensifying pressure on coding-driven economics and elevating RADV, documentation integrity, and compliant population health workflows as core strategic priorities rather than back-office functions. For ACOs, risk-bearing providers, and payers, the tension is clear: MA remains a dominant value-based growth channel, but future margin will depend less on coding lift and more on defensible quality performance, encounter-data discipline, Stars execution, and care models that can withstand federal scrutiny under CMS and HHS leadership.

CMS under the Trump administration is accelerating CMMI’s shift from episodic pilots toward scalable, technology-enabled and mandatory payment models: the ACCESS Model is being expanded to additional chronic care tracks including heart failure, COPD, substance use disorders and tobacco use, while digital health and AI participants such as Oura and Counsel Health signal a stronger push to test remote monitoring, wearables and virtual care infrastructure in Medicare chronic disease management ([HFMA](https://www.hfma.org/payment-reimbursement-and-managed-care/cms-access-model-expansion/)). At the same time, the finalized GLOBE drug payment model and renewed momentum around CJR/CJR-X point to a broader strategy of using mandatory or quasi-mandatory models to pressure specialty, hospital and drug spending—creating new upside for systems with mature care redesign capabilities, but heightened exposure for hospitals, specialists, ACOs and payers that have not aligned post-acute management, pharmacy strategy and data operations ([Fierce Healthcare](https://www.fiercehealthcare.com/payers/cms-finalizes-model-aims-bring-most-favored-nation-pricing-part-b)).

ACO strategy is shifting from participation growth to operating-model maturity: MSSP now serves a record 12.6 million traditional Medicare beneficiaries across 511 ACOs, with reported net Medicare savings and shared savings reinforcing why health systems are investing in coordinated outreach, attribution management, and centralized population health infrastructure ([HFMA](https://www.hfma.org/finance-and-business-strategy/from-fragmented-outreach-to-coordinated-action-building-a-value-based-care-operating-model/)). At the same time, risk-bearing ACOs are moving beyond primary-care management into specialty contracting, technology enablement, and more sophisticated financial arrangements—areas where ACO REACH and MSSP participants will face increasing pressure to align specialist incentives, data workflows, and downside-risk economics ([HCTTF Specialty Contracting Playbook](https://hcttf.org/specialty-contracting-playbook/)). The strategic tension for executives is that scale is improving the business case for value-based care, but success increasingly depends on execution capabilities—AI-enabled analytics, specialty integration, and actuarially sound contracting—rather than simple ACO enrollment growth.

CMS is moving bundled payments back toward mandatory, scaled episode accountability: recent coverage points to CJR’s reported $180M in savings as the rationale for broader expansion, while CMS has finalized the Comprehensive Care for Joint Replacement Expanded Model (CJR-X) beginning Jan. 1, 2028, with participant lists now emerging and hospitals preparing 2027 operating plans around orthopedic episodes, post-acute leakage, and downside-risk exposure ([TechTarget](https://www.techtarget.com/revcyclemanagement/news/366651340/CJR-Models-180M-savings-pave-way-for-nationwide-expansion); [AHA](https://news.google.com/rss/articles/CBMiwgFBVV95cUxQc3J0MW1vb3Y3Z05COGFjQlI3U0hRQ0lNZFM4bWxTR3dPUHpnWDEwNllNN1kxUlZuWVNabDEwOXFuTGcyR2pYeThBMnlZaVRvRGt5cmZ3WGx3czhLNXJid193cXdyWnh2N2RqZ3NrUmlQYm02dkxJbEVBZmc4ZkpFdHE0Y3Y3cVZYWTNTOG84ekx3ZE1pSXJsQU9fTlgzZExEMzhyVkNNaW5TbW5jZg).

The Trump administration’s CMS is moving the $50 billion Rural Health Transformation Program from statute into state implementation, with early awards and spending plans emphasizing rural workforce pipelines, community health centers, technology, and care delivery infrastructure—positioning the program as a major rural access lever but not a full offset to Medicaid financing pressure created by the 2025 reconciliation law. For VBC stakeholders, the strategic issue is whether states use RHTP grants to build durable population-health capacity—primary care, behavioral health, care coordination, telehealth, and data infrastructure—or to backfill near-term rural hospital and safety-net gaps, a tension underscored by KFF’s analysis of the program’s scale and distribution and provider-law commentary warning the funding may be insufficient relative to Medicaid reductions ([KFF overview](https://www.kff.org/medicaid/a-closer-look-at-the-50-billion-rural-health-transformation-program/); [Hooper Lundy analysis](https://hooperlundy.com/rhtp-funding-paving-way-for-improved-rural-health-care-but-infusion-deemed-insufficient-to-assuage-rural-hospitals-medicaid-woes/)). Community health centers and rural training programs are also positioning for these funds, with NACHC tying rural access strategy to expansion of Teaching Health Center GME and CHC-led residency capacity—important for ACOs and Medicaid managed care plans that need local primary care supply to execute risk-based contracting.

Behavioral health integration is moving from a clinical aspiration to a payment-design problem for VBC stakeholders: NCQA argues that fee-for-service still undervalues team-based behavioral health and weakens the business case for integrated primary care, while states such as North Carolina are using practice transformation supports and Medicaid-oriented models to accelerate collaborative care adoption ([NCQA](https://www.ncqa.org/blog/aligning-payment-and-measurement-behavioral-health/), [NASHP](https://nashp.org/behavioral-health-integration-in-action-north-carolina-accelerates-collaborative-care-adoption-through-practice-transformation-supports/)). At the same time, Medicaid and population-health operators are positioning high-need behavioral health management as a utilization-control strategy—Mental Health Cooperative reports a model associated with 33% fewer ED visits and slower cost growth—reinforcing that ACOs, Medicaid MCOs, and primary care groups will need stronger behavioral health measurement, care coordination, and prospective payment infrastructure to make integration financially durable.

Specialty care VBC is moving toward more targeted, politically scrutinized payment redesign: CMS finalized a narrower GLOBE Part B drug pricing model, reducing oncology drug-pricing exposure and financial disruption while preserving a test of specialty-drug accountability in Medicare Part B ([ASCO](https://news.google.com/rss/articles/CBMivwFBVV95cUxNdXZ3cU0wSHhMVlRtTkM0N2ozWHh4ZzE4VFpOS04tRzg4RDFlR3U1cUdVZWc2M1EzWE11aXhkaFFndnhJc1FVNzN3dEZwdVFzN1EzQVpITnItLUM2am11M3BhV0piVTJIYlVEZmhmUGVFdXkwMDhyd2hWVF80NURiUml5aTB5bUJycWRXNWZMX0pvUGdWbWtkcnJNNEQ4SFhnUHVLWE1qaVJzSEZRODZOVXg4MDI2OWRnRVdXLWFmRQ?oc=5)). At the same time, oncology and kidney stakeholders are positioning specialty models as complements—not carve-outs—to ACO strategy, with continued emphasis on bundled oncology payments, the post-Enhancing Oncology Model pathway, and ensuring kidney care is embedded in Medicare’s ACO strategy.