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ACO Shadow Bundles: An Enhanced Focus on Episodes of Care

Learn the latest shadow bundle data updates to Shared Savings Program ACOs from CMS.
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In December 2023, the Centers for Medicare & Medicaid Services (CMS) announced shadow bundle data would be distributed to all Shared Savings Program Accountable Care Organizations (ACOs) starting in February 2024. The data will include episode-level claims files, target prices, and summary reports.

The shadow bundles will be created for ACO-attributed beneficiaries using the Bundled Payments for Care Improvement Advanced (BPCI-A) methodology and is purely informational. In other words, there will not be a reconciliation process or an impact on ACOs’ shared savings calculations. The provision of this data further supports the plans of the Center for Medicare and Medicaid Innovation (CMMI) for a mandatory bundled payment model to be implemented in 2026, at the conclusion of the voluntary BPCI-A model.

This data will serve as yet another tool for value-centric enterprises to leverage as they prioritize the delivery of value-based care (VBC) and drive strategic, operational, and financial planning decisions.

Path Forward

The robustness of the shadow bundle data will give ACOs a competitive advantage over other healthcare organizations not currently participating in an ACO or the BPCI-A model. ACOs that acquire the data analytic capabilities to appropriately analyze these files will see a host of benefits, including the following:

  • Potential Mandatory Bundle Preparation: If mandatory bundles are implemented in 2026 or later, then organizations will benefit from familiarizing themselves in advance with the concept of managing patients via bundles, focusing on levers that impact care improvement and cost reduction in episodic models, and developing and implementing strategies for future success.
  • Service Line & Specialty Care Strategies: Bundles within the BPCI-A model are grouped by service line and include both medical and surgical bundles. Service lines include cardiac, gastrointestinal, orthopedics, spine, medical and critical care, and neurological. The new ACO shadow bundle data can be leveraged to analyze service line trends and develop associated strategies to drive hospital-based improvements that complement the ACO’s focus on primary care to manage total cost of care of attributed beneficiaries.
  • Service Line & Specialist Engagement: With service line focused strategies comes the opportunity for greater engagement with specialists through transparent data sharing. Access to actionable information enables providers to make informed decisions, streamline workflows, and enhance care coordination. The availability of comprehensive and timely information supports evidence-based practice, collaboration, and informed decision making, ultimately leading to better patient care and satisfaction. Consideration can be given to driving further accountability by establishing clear metrics and benchmarks that physicians are expected to meet to achieve performance-based incentives.
  • ACO Shared Savings Increase: The shadow bundle data will allow ACOs to more appropriately risk stratifying the moderate to high-cost subset of their ACO population with certain acute events. With this insight, users can better identify expenditure and utilization reduction opportunities and develop more targeted strategies to better manage total cost of care.


The addition of the shadow bundle data to the already robust Shared Savings Program data opens the door to more comprehensive strategies spanning two model types, episode-based and total cost of care. With this combination, organizations will have the ability to engage additional providers, e.g., hospital-based, post-acute, etc., as well as primary care. In addition, interventions can be better targeted based on the beneficiary, e.g., moderate to high-cost acute care episodes versus low-cost, healthy patients, with a focus on discharge planning, care coordination, and post-acute management in addition to prevention and disease management.

Reach out to a healthcare consultant at FORVIS today to understand how your ACO may benefit from the shadow bundle data.

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