Health Care Policy
What is Policy at Aledade?

Often when people hear “policy,” they think of all of the compliance issues ACOs must ensure they are following. Compliance is important, but policy at Aledade is about the sustainability of independent and community-based practices, primarily through analysis and advocacy. The policy team is here to analyze any relevant rules, regulations, and legislation that impacts physician-led ACOs – and ultimately advocate for outcomes that work best for practices to not only survive, but thrive.

Aledade policy team standing as a group



We get “in the weeds” to comment and influence the rules and regs so you don’t have to….and more broadly, we use real-world data and outcomes from the practices we work with to promote primary care, value-based care, and we advocate for and show the value of independent practices.  

Tangible Outcomes

Advocating for Physician Fee Schedule improvement in benchmark calculations for Medicare Shared Savings Program ACOs, including areas around risk score caps, the rural glitch, and quality measurement.

The “rural glitch” penalizes certain ACOs in rural areas and other health professional shortage areas, when they are successful at delivering better care at lower costs. This happens because an ACO’s beneficiary population is included in the regional trend calculation, so they are penalized for making improvements to patient care and achieving savings when CMS determines their benchmark the following year. When an ACO reduces costs, this carries over to also reducing the region's costs; this effect increases the more beneficiaries an ACO has in its region. Unfortunately, many of these ACOs are disproportionately located in areas where there is a shortage of health professionals, such as rural areas and underserved communities, where CMS has stated it wants to see more participation in value-based models.

At Aledade, we believe there is still opportunity for significant growth in ACOs. In the fall of 2021, we outlined in Health Affairs the case for using the MSSP as a “chassis” for innovation. In 2022, we followed up with a series of policy briefs to engage policymakers to continue to build on the success in four ways: incorporating desired elements from the Next Generation ACO model, primary care capitation, value-based insurance design, and addressing inequity in health care.

Aledade/s retrospective case study, published in the American Journal of Accountable Care, compares the results of five Aledade MSSP ACOs to both ACO benchmarks and regional competitors over a four-year period. During this timeframe, "The cohort is estimated to have prevented 10,917 hospitalizations, 19,338 emergency department visits, and 8859 skilled nursing facility visits, compared with the region. This is believed to be largely driven by improvements in care transitions and preventive care, such as annual wellness visits, which the cohort of ACOs performed at 265% above the regional average in 2019."

The case study demonstrates that although results take time to achieve, value-based care has the potential to meaningfully reduce costs and improve the quality of care delivered by increasing preventive care and reducing utilization of acute services.

The pandemic created unprecedented financial challenges for the health care system and was especially difficult for primary care practices, who generally operate on slim margins under normal circumstances. Aledade advocated for independent primary care practices to be able to take advantage of the financial support from federal relief program rulings. We continue to ensure our partnering practices understand the telehealth landscape and additional flexibilities during the Public Health Emergency.

Showed CMS that Admission, Discharge, and Transfer (ADT) notices improve health and save money through compiling data and research, and broad advocacy. In March 2020, CMS included ADT notices as a condition of participation with Medicare under Medical Record services.  

Regional benchmarking gives a more accurate picture of the savings ACOs provide to Medicare, and rewards ACOs that do a better job of controlling costs than their neighbors.

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State Policy Program

Engage in Advocacy in Your Region


Aledade’s growing State Policy Program keeps ACO member practices informed of important policy issues in their region and provides a platform for clinicians and practice leaders in independent and community-based primary care practices to inform local policy outcomes. Learn More

Published Articles

More Than “Beating the Benchmark”: 5 Medicare ACOs, 2015-2019

By Douglas A. Streat, Travis Broome, Brian Chiglinsky, and Farzad Mostashari; Published in AJMC, September 2021

A Proven Path To Re-Energizing Medicare Innovation

By Travis Broome; Published in Health Affairs Forefront, October 2021

The Future of Accountability for Total Cost of Care

By Travis Broome; Published in the AJMC Blog, December 2021

Our Health Care System Wasn’t Designed To Support Telehealth. Now It’s Time For A Makeover

By Sean Cavanaugh; Published in Health Affairs Blog, December 2020

Medicare Payment Reform’s Next Decade: A Strategic Plan For The Center For Medicare And Medicaid Innovation

By Farzad Mostashari and Bob Kocher; Published in Health Affairs Blog, December 2020

Minimizing Administrative Burden in the Provider Relief Fund: Spending Money on Care, Not Accounting

By Travis Broome and Britainy Barnes; Published by AJMC, June 2020

Leveraging Payment Reforms For COVID-19 And Beyond: Recommendations For Medicare ACOs And CMS’s Interim Final Rule

By Travis Broome; Published in Health Affairs, May 2020

Medicare Steps In to Make Transitions of Care Safer

By Travis Broome; Published by AJMC, March 2020

Payment Designed for People: Introducing the Primary Care Outcomes Model

By Travis Broome and Farzad Mostashari; Published in New England Journal of Medicine, October 2018