VBC INTEL
Policy Analysis  /  MSSP Risk Adjustment  /  PY2024

The MSSP RAF Ceiling Just Changed.
Most ACOs Don’t Know It Yet.

Cohort 135 mainstream MSSP ACOs, PY2024Source CMS MSSP Public Use FileAuthor Cameron Ginn, MPH — VBC CPI
$428M
Net annual benchmark suppression
29%
ACOs under a tighter ceiling
5
ACOs lost MSR clearance
$26M
Combined forfeited settlement
The Policy Change

One formula change. Asymmetric consequences.

For years, MSSP ACOs operated under a straightforward ceiling on positive HCC adjustment: risk scores could not grow more than 3% above the baseline year. Documentation programs were calibrated to it. Coding targets were set against it.

For any ACO entering a new agreement period in PY2024 or later, that ceiling no longer applies in its prior form. CMS replaced the flat 3% cap with a segment-level demographic ceiling that moves with each ACO's own population dynamics.

Pre-2024 — Deprecated for new agreements
Flat 3% Cap — Program-Wide
HCC_PY ≤ HCC_BY3 × 1.03

A single ceiling applied uniformly across all enrolled populations. One target. Every segment, every ACO.

→
PY2024 onward — Active
Segment-Level Demographic Ceiling
HCC_PY ≤ (DMGR_PY / DEMOG_HCC_BY3) × 1.03

A dynamic, population-specific ceiling per segment. Moves with demographic acuity. Not a fixed percentage above baseline.

Applied per segment  ·  ESRD  ·  AGND  ·  DIS  ·  AGDU

The direction of impact is not uniform. If an ACO's demographic acuity grew between baseline years and PY, the new ceiling is more generous than the flat 3% cap. If demographic acuity declined — or if the ACO was already coding aggressively in the baseline period — the effective ceiling tightened materially. Two ACOs can run the same documentation program and land on opposite sides of this change.

Program-Wide Findings

How the cohort actually split.

Modeled across 135 mainstream MSSP ACOs entering new agreement periods in PY2024. Five LTC-centric outliers excluded (composite flat benchmark above $2,000 PMPM) to preserve comparability across the mainstream program population.

29%
Hurt — 39 ACOs

Operating under a tighter effective ceiling than the flat 3% methodology would have produced. Benchmark suppressed relative to prior rules.

34%
Helped — 46 ACOs

Operating under a more generous ceiling than before. Demographic acuity growth between baseline years and PY created additional headroom.

37%
Unaffected — 50 ACOs

Cap was never binding either way. These ACOs were not coding close enough to the ceiling under either methodology for the change to matter.

The asymmetry is stark. Being hurt by the new methodology costs a median $2.9M annually. Being helped delivers a median $196K lift. For every dollar of benchmark value the new formula adds to helped ACOs, it removes roughly fifteen dollars from hurt ones.

Hurt ACOs — N=39

Median annual suppression$(2.9M)
Median attributed lives17,189
Median benchmark PMPM$1,117
Max annual suppression$(83M)Single ACO, Very Large cohort
MSR clearance rate62%Suppression hits even clearing ACOs
Total annual suppression$(456M)

Helped ACOs — N=46

Median annual lift+$196K
Median attributed lives9,925
Median benchmark PMPM$1,011
Max annual lift+$3.1MSingle ACO, Mid cohort
MSR clearance rate63%Nearly identical to hurt cohort
Total annual lift+$28M
VBC Contract Performance Intelligence — RAF Ceiling Analysis — PY2024 — N=135
Size & Revenue Segmentation

This is not a small-ACO problem.

The hurt cohort skews large. 41% of hurt ACOs are Large (15K–40K lives) and 18% are Very Large (40K+ lives). The Very Large hurt ACOs face a median annual suppression of $23M — at scale, the formula change is a material financial event. Helped ACOs are overwhelmingly smaller, and the benefit is modest relative to the harm on the other side.

Size CohortACOsShareMedian Impact
Hurt ACOs — N=39
Small — under 5K lives25%$(1.7M) / yr
Mid — 5K to 15K lives1436%$(2.4M) / yr
Large — 15K to 40K lives1641%$(2.3M) / yr
Very Large — 40K+ lives718%$(23.1M) / yr
Helped ACOs — N=46
Small — under 5K lives00%—
Mid — 5K to 15K lives3270%+$196K / yr
Large — 15K to 40K lives1430%+$210K / yr
Very Large — 40K+ lives00%—

No Very Large ACO benefited from the new methodology. Every Very Large ACO affected was hurt. Among the 39 hurt ACOs, 72% carry benchmarks above $150M annually — these are not marginal programs.

Patient Complexity Profile

The new ceiling penalizes higher-complexity ACOs.

Every hurt ACO in the cohort falls into the Mid or High HCC tier. Not a single Low HCC ACO was hurt by the methodology change. The helped cohort is overwhelmingly Mid HCC. The new formula disproportionately affects ACOs managing more medically complex populations — the ones whose benchmark integrity arguably matters most.

Hurt ACOs — HCC Tier

Low HCC0  0%
Mid HCC24  62%
High HCC15  38%
Very High HCC0  0%

Helped ACOs — HCC Tier

Low HCC4  9%
Mid HCC41  89%
High HCC1  2%
Very High HCC0  0%
MSR Clearance Impact

Five ACOs lost their payout. The contract structure eliminated it.

The benchmark suppression produced by the new methodology doesn't just reduce settlement size — in five cases it eliminated it entirely. These ACOs generated real gross savings. Their clinical teams performed. Under the flat 3% cap, each would have cleared their MSR threshold and earned a shared savings payment. Under the new demographic ceiling, the suppressed benchmark moved the threshold out of reach.

5
ACOs lost MSR clearance

Generated positive gross savings but missed MSR threshold solely due to the new ceiling methodology. Would have cleared under the flat 3% cap.

$26M
Combined forfeited settlement

Implied lost shared savings payment across the five ACOs. Clinical performance was sufficient. Contract mechanics eliminated the payout.

5
Additional near misses

Missed MSR under both methodologies, but the gap to threshold was materially widened by the new ceiling — pushed further from a payout they were already close to.

62% of hurt ACOs cleared MSR despite the suppression. The benchmark impact is not visible in settlement outcomes for the majority of affected ACOs — it is silently reducing the size of a payout they still received. The suppression is real whether or not it crosses the MSR threshold. For the five that crossed it, the consequence was total.
VBC Contract Performance Intelligence — MSR Clearance Analysis — PY2024
Segment Analysis

AGND drives the majority of the impact.

AGND — Aged, Not Dual-Eligible — represents the dominant attributed population for most MSSP ACOs, typically 85% or more of total attributed lives. It is also the segment where the new methodology bites hardest.

25
ACOs — AGND suppressed

AGND segment benchmark suppressed by the new demographic ceiling relative to the flat 3% cap. AGND is the highest-lives segment for most ACOs — suppression here compounds at scale.

4
ACOs — AGND lifted

Only 4 of 135 ACOs saw AGND benchmark lift from the new methodology. The change is structurally unfavorable for AGND at the population level.

6:1
Hurt-to-helped in AGND

For every ACO that benefited in AGND, six were suppressed. In the segment that matters most by volume, the new methodology is a net negative by a wide margin.

Why AGND is the highest-risk segment under the new formula: AGND populations tend to have stable demographic acuity with meaningful HCC coding history. ACOs that coded well in baseline years built a high BY3 HCC score — which the new formula uses as the denominator in the ceiling calculation. A high BY3 HCC means a lower ceiling ratio, which means less room for HCC growth in PY before hitting the cap. Strong historical coding becomes a structural headwind under the new methodology.

Which side of this is your ACO on?

The formula change is invisible in most settlement outcomes, but it is quietly moving benchmarks in both directions. The reconstructor shows where any ACO landed in PY2024 under the current rules. A full analysis models the ceiling by segment for your specific population.

Look up your ACO → Start a Conversation →