Emerging Regulatory and Market Trends for Accountable Care Organizations
- May 02, 2025
- Anthony Del Rio , Kirkland & Ellis LLP
- Ruan J. Meintjes , Kirkland & Ellis LLP
- Marie Macaulay , Kirkland & Ellis LLP
On March 12, 2025, the Center for Medicare and Medicaid Innovation (CMMI) announced it is terminating four Accountable Care Organization (ACO) models early, with a plan to wind down these models by year end. The Centers for Medicare & Medicaid Services (CMS) estimates that early termination of these programs will amount to $750 million in savings. Concurrently, major health care organizations have wound down or sold their ACOs. The combination of CMMI’s announcement and market participants’ notable movements raise questions for ACOs and value-based care programs more broadly. This article explores the evolving landscape of ACOs from a legal and regulatory perspective, focusing on the uncertainties that the year 2025 brings to these entities and their sponsoring organizations.
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