By Surabhi Dangi-Garimella, PhDd

The Centers for Medicare and Medicaid Innovation—also known as the Innovation Center—wants to redesign the recently launched Global and Professional Direct Contracting (GPDC) Model to encourage care coordination and improve the quality of care, especially among underserved Medicare populations. With this priority, the Innovation Center has proposed renaming GPDC as the Accountable Care Organization Realizing Equity, Access, and Community Health (ACO REACH) Model starting January 1, 2023, and is currently soliciting stakeholder feedback and new model participants.

GPDC’s objectives are clear: 

  • Move away from traditional fee-for-service Medicare and transform risk-sharing agreements such that payments are tied to patient quality of care
  • Empower enrollees to be better engaged in their healthcare 
  • Reduce administrative burden on health care providers

GPDC, which launched on April 1, 2021, has 53 participating entities across 38 states, D.C., and Puerto Rico. These participants have to agree to the requirements of the ACO REACH Model to continue their participation come January 1, 2023. 

What’s Different About ACO REACH?

ACO REACH will run for four performance years (2023-2026) 

  • Promote health equity and address disparities faced by underserved populations
  • Continue to encourage provider-led organizations to participate in risk-based care models
  • Protect beneficiaries and the model with more participant vetting, monitoring, and more transparency

CMS has developed a detailed comparative chart highlighting anticipated policy changes with ACO REACH. Here are some key changes:

  • Governance: Increased governing board voting rights for participating providers (75% control instead of 25%), plus room for a consumer advocate and a beneficiary representative on the voting board 
  • Healthy equity: Greater emphasis on health equity, including:
    • Collecting data on patients’ social needs
    • Health equity benchmark adjustment to support care delivery and care coordination for patients from underserved communities
    • Development of a Health Equity Action Plan
  • Transparency and beneficiary protection: 
    • Increased vigilance over any inappropriate coding practices, misuse of beneficiary data, and anticompetitive behavior
    • Review marketing material to ensure beneficiaries understand they have the freedom of choice (that they can opt-out of participating in the model)

The model offers three types of participants:

  • Standard ACOs: Participating organizations would have experience with Original Medicare patients. They may or may not have participated in other shared savings models offered by the Innovation Center (Next Generation ACO or Pioneer ACO) or in the Medicare Shared Savings Program.
  • New Entrant ACOs: Participating organizations may not have served Original Medicare populations and will depend on voluntary alignment.
  • High Needs Population ACOs: ACOs that serve Original Medicare patients with complex needs, including dual-eligible enrollees 

Organizations Unhappy With ACO REACH 

A wide spectrum of more than 200 healthcare organizations have signed on a letter addressing HHS secretary Xavier Becerra and CMS Administrator Chiquita Brooks-LaSure, expressing their concern with ACO REACH. Specifically, the signees believe that the new model might backfire on being more equitable and instead provide “more opportunities for middlemen to profit.” The letter raises concern that most seniors will be automatically enrolled into the model if their primary care provider participates in it and opting out would require them to change their PCP, which may be burdensome for the seniors. Additionally, there is worry that the capitated payment model will create incentives for middlemen that will restrict senior care while draining Medicare of billions of dollars. 

The application period for participating in ACO REACH ends April 22, 2022. 


Surabhi Dangi-Garimella, Ph.D. is a biologist with academic research experience, who brings her skills and knowledge to the health care communications world. She provides writing and strategic support to non-profit groups via her consultancy, SDG AdvoHealth, LLC.