Policy & Regulatory Changes

CMS under the Trump administration is accelerating mandatory and technology-enabled payment models: CJR’s reported $180M in savings is strengthening the case for broader bundled-payment expansion, while TEAM is already shifting episode economics toward outpatient care and tighter post-acute/home health coordination. At the same time, CMS is expanding the ACCESS Model into additional chronic-condition tracks for 2027—COPD, substance use disorder, tobacco cessation and others—signaling a longer-term push to pair digital infrastructure with longitudinal chronic care management and risk-bearing provider participation (ACCESS expansion).

Regulatory pressure is also rising around coding, drug spend and primary care economics: OIG scrutiny of Medicare Advantage diagnosis submissions reinforces risk-adjustment compliance risk, CMS’s finalized GLOBE drug pricing model adds another cost-control lever, and proposed 2027 Physician Fee Schedule changes would begin rebalancing Medicare payment toward primary care and accountable care participation (primary care payment changes). For ACOs, health systems and payers, the strategic signal is clear: CMS is rewarding scalable chronic care, primary care capacity and episode accountability while tightening oversight of documentation, MA coding and high-cost therapeutics.