By:
Kathryn Anderton, BSN, RN, BC-RN, CCM
April 16th, 2026
What You’ll Learn in This Article In its 2026 Final Rule, CMS acknowledges that value-based care cannot be scaled to our broader system if outcomes depend on which provider, which workflow, or which system a patient happens to touch. Accountable Care Organizations are still operating with person-level infrastructure: For example, engagement depends on individual champions, or analytics describe problems but don’t drive action ACOs that thrive will be the ones who have intentionally removed friction between insight and action. Bridges Health Partners uses ThoroughCare, a value-based care delivery platform, to scale population health management across multiple independent health systems. This ACO shows how using software designed and supported by a Clinical Advisory Team can drive better outcomes. Most commentary on the 2026 Medicare Physician Fee Schedule focuses on what changed, such as: Shorter glide paths Adjusted benchmarks Modified quality scoring Expanded EUC definitions All of that is accurate. And all of it misses the larger story. The more important story is this: CMS is no longer optimizing the Medicare Shared Savings Program solely for participation. It is optimizing it for reliability. Reliability of outcomes Reliability of execution Reliability of accountability That shift is subtle, structural and far more consequential than any single policy update. The CMS 2026 Final Rule Emphasizes a Need for Uniform Performance Measures If you read the rule holistically, a pattern emerges that isn’t explicitly stated but is impossible to miss once you see it. CMS is systematically eliminating variability as an acceptable explanation for performance. Long one-sided runways are shortened Quality scoring is simplified and deduplicated Attribution and reporting populations are tightened Alternative quality standards are actively monitored Cyber events are formally acknowledged as operational risk Ownership changes are accommodated, but tracked in real time This is not CMS being punitive. It is CMS acknowledging something uncomfortable: You cannot scale value-based care if outcomes depend on which provider, which workflow, or which system a patient happens to touch. From CMS’s perspective, variability equals unpredictability, and unpredictability equals financial risk to the Medicare Trust Funds. Why This Is Harder Than It Sounds for Accountable Care Organizations (ACOs) Here’s the part most policy analysis glosses over. CMS is holding ACOs accountable for system-level performance, but most ACOs are still operating with person-level infrastructure. Care consistency lives in people’s heads Engagement depends on individual champions Quality success relies on post-period cleanup Analytics describe problems but don’t drive action That worked when MSSP allowed long learning curves and retrospective forgiveness. It does not work when: Risk accelerates Benchmarks tighten Quality is monitored continuously Engagement is expected, not optional CMS 2026 does not create this tension. It simply exposes it. What CMS Is Really Signaling Beneath the Policy Language of the Final Rule The most important message in the 2026 rule is not explicitly stated. CMS is no longer asking whether organizations understand value-based care. It is asking whether they can execute it consistently. That distinction matters. Execution at scale requires more than strategy. It requires alignment between people, process and technology at the point of care. It requires systems that translate insight into action without relying on extraordinary effort to succeed. This is where many organizations feel the gap most acutely. Not at the policy level, but at the operational one. ThoroughCare Sits at the Operational Level of Value-based Care (And Why That Matters for Uniform Reporting) ThoroughCare is often described as a care management platform. That description is accurate, but incomplete. At a deeper level, ThoroughCare functions as an execution layer. Our software and Clinical Advisory Services connect CMS policy intent to real-world provider behavior where care actually happens. CMS 2026 assumes organizations can: Identify the right patient at the right moment Trigger timely, evidence-based interventions Standardize care without stripping clinical autonomy Engage members in ways that change utilization, not just enrollment Monitor quality prospectively rather than repairing it retrospectively Those capabilities are no longer aspirational. They are implicit in how CMS now evaluates success. ThoroughCare exists to support that execution — not by replacing clinical judgment or operational strategy, but by making them repeatable, measurable and scalable across diverse networks. How ThoroughCare Helps Bridges Health Partners Coordinate Care at Scale Bridges Health Partners is an ACO in western Pennsylvania that uses ThoroughCare's care coordination platform to manage its patient population. By implementing standardized care plans, clinical assessments, and analytics tools, Bridges Health Partners has: Improved patient engagement Aligned providers around value-based care Scaled population health management across multiple independent health systems In a specific patient case, care managers with Bridges Health Partners helped a patient with coronary artery disease, long-term diabetes (20+ years) and nephropathy lose 14 pounds and reduce their A1C 8.1% to 6.4%. Why CMS 2026 Rewards Execution, Not Strategy One of the most subtle but consequential shifts in the rule is the expanded monitoring of alternative quality performance standards alongside traditional standards. This signals a move away from “did you report” toward “did you actually perform, consistently, across the network.” Performance is no longer episodic. It is behavioral. That requires: Embedded workflows, not external programs Real-time visibility, not quarterly retrospectives Standardization that travels with the patient, not the provider Engagement that is operational, not aspirational ThoroughCare’s value is not that it identifies risk. Many tools do that. Its value is that it closes the loop: Analytics trigger outreach Outreach triggers enrollment Enrollment triggers standardized care plans Care plans trigger measurable actions Actions feed quality, cost and engagement outcomes automatically This is not about technology for its own sake. It is about creating the conditions where good care can happen consistently, regardless of organizational complexity. The Flagship Takeaway CMS 2026 delivers a quiet but unmistakable message to ACO leadership. If success depends on exceptional effort rather than repeatable systems, the model will not hold. CMS is not asking organizations to work harder. It is asking them to work differently. The next phase of the Medicare Shared Savings Program is built for reliability — reliability of execution, reliability of outcomes and reliability at scale. Organizations that thrive under CMS 2026 will not be the ones with the most sophisticated policy interpretations. They will be the ones who have intentionally removed friction between insight and action. ThoroughCare Knows How ACOs Can Act on Strategy Across ACOs and risk-bearing organizations that have operationalized care management, analytics and engagement through a unified execution layer, a consistent pattern emerges. In ThoroughCare-supported environments, that alignment has translated into: 10–15x ROI for care coordination programs 40–50 percent enrollment in Chronic Care Management programs Measurable reductions in avoidable utilization and downstream cost Network-wide consistency across hundreds of organizations and thousands of patients These outcomes are not driven by any single program or policy advantage. They emerge when care delivery is structured to be repeatable, measurable and scalable.
See how ThoroughCare simplifies Medicare's most complex programs.
By:
Daniel Godla
June 24th, 2025
Value-based objectives are more easily met for patients with one chronic condition. However, patients living with multiple chronic conditions (MCCs) typically have a more complex clinical picture. One where the standard value-based care framework often falls short, demanding a different approach than Medicare care management programs were created to address.
Value-Based Care | Care Management
By:
Kathryn Anderton, BSN, RN, BC-RN, CCM
April 24th, 2025
Periodic performance reviews are crucial to ensuring any care management program meets its objectives. However, creating a process and determining which data to focus on can be challenging for a new or expanding program.
Annual Wellness Visit | Value-Based Care
By:
Kathryn Anderton, BSN, RN, BC-RN, CCM
April 16th, 2025
In this video, we discuss how Annual Wellness Visits — or AWVs — can be a powerful gateway to enrolling patients in care management programs like Chronic Care Management (CCM) and Remote Patient Monitoring (RPM). We’ll show you why AWVs are more than just a Medicare requirement — they’re a key touchpoint for identifying patient needs, improving outcomes, and boosting reimbursement for your practice. If you're looking to deliver more holistic care and grow your value-based care efforts, you're in the right place.
Value-Based Care | Social Determinants of Health
By:
Kathryn Anderton, BSN, RN, BC-RN, CCM
February 18th, 2025
Health equity can play a vital role in enhancing and optimizing care delivery across populations.
Value-Based Care | Behavioral Health Integration
By:
Daniel Godla
February 5th, 2025
The Centers for Medicare and Medicaid Services (CMS) has updated the Final Rule for Behavioral Health Integration (BHI) for 2025. While there were no major changes to the BHI program rules and regulations in this Final Rule, it is significant that, for the first time, Rural Health Clinics and Federally Qualified Health Centers are now permitted to bill for the BHI CPT codes, just like other fee-for-service practices. Additionally, there are updated reimbursement rates for these CPT codes.