MSSP changes in the 2025 MPFS final rule

CMS published a fact sheet to provide organizations with more information on upcoming changes to the Medicare Shared Savings Program (MSSP). The agency finalized several MSSP policies in the 2025 Medicare Physician Fee Schedule (MPFS) final rule, including the establishment of a prepaid savings plan, a new health equity benchmark, and new financial methodologies.

CMS will initiate a prepaid shared savings plan for accountable care organizations (ACO) with a background of earned savings under the MSSP. Eligible ACOs who apply for and receive these advances must follow specific spending guidelines, according to the fact sheet. At least 50% of the prepaid savings must be spent on direct beneficiary services not payable under traditional Medicare, and up to 50% of the savings can be spent on staffing and infrastructure.

ACOs that receive these advance payments will repay them through earned shared savings, according to the fact sheet. However, those that are unable to use this repayment method must repay any outstanding balance directly to CMS at the end of their agreement period.

Eligible ACOs can apply for the prepaid shared savings plan during the annual application cycle, and the initial cycle will have a start date of January 1, 2026.

CMS will also establish a Health Equity Benchmark Adjustment (HEBA) to provide greater financial incentive for ACOs to serve more beneficiaries from underserved communities and remain in the MSSP. Beginning on January 1, 2025, the agency will adjust an ACO’s historical benchmark using a HEBA based on its proportion of certain low-income or dually eligible beneficiaries, according to the fact sheet. However, the benchmark will ultimately be adjusted based on the highest of three values for which the ACO is eligible (HEBA, positive regional adjustment, or prior savings adjustment).

CMS finalized a methodology to account for impacts related to improper payments in expenditure recalculations used in financial reconciliation upon the reopening of a payment determination, according to the fact sheet. Additionally, the agency finalized a methodology for excluding payment amounts for certain codes exhibiting significant, anomalous, and highly suspect billing activity. These policies reflect provisions in a separate final rule, published in September, on MSSP financial calculations.

Before finalizing these changes to the MSSP, CMS revealed that the program yielded over $2.1 billion in net savings in 2023, representing the most savings in the program’s history. MSSP ACOs earned record-breaking shared savings payments and displayed statistically significant improvement in several quality measures in 2023, according to the press release.

Revenue integrity professionals should review the 2025 MPFS final rule for more information on upcoming MSSP changes. Read NAHRI’s initial analysis of the rule to learn about changes to payment rates, behavioral health services, telehealth requirements, and more.