New ACO Shadow Bundles to Leverage Claims Data

Unlocking the Potential of Accountable Care Organization Shadow Bundles 

In a healthcare industry increasingly focused on value over volume, the Centers for Medicare & Medicaid Services (CMS) have introduced a strategic initiative set to revolutionize the way Accountable Care Organizations (ACOs) understand and manage care delivery. Starting February 2024, CMS now distributes shadow bundle data to all participants in the Medicare Shared Savings Program (MSSP) and the ACO Realizing Equity, Access, and Community Health (REACH) models. This marks a pivotal shift towards a more data-driven, accountable approach to healthcare provision, signaling both opportunities and challenges in navigating this new landscape. 

The Purpose of Shadow Bundles 

Shadow bundles represent a novel way of structuring payments within an ACO’s attributed population. Unlike traditional bundled payments, which involve fixed-price agreements for a predefined episode of care, shadow bundles are informational tools. They are built using CMS’s Bundled Payments for Care Improvement – Advanced (BPCI-A) episode methodology, covering a wide range of clinical episodes and accounting for a significant portion of healthcare expenditures. 

By providing detailed episode-level claims files, target prices, and summary reports on a monthly, quarterly, and annual basis, shadow bundles aim to offer insights into hospital and individual specialist performance. This data, though purely informational for now, primes ACOs for a future where bundled payments could become a mandatory part of their operating models, expected by 2026. 

Leveraging Shadow Bundles for Strategic Advantage 

For MSSP and ACO REACH participants, the shadow bundles data represents a goldmine of potential insights. Here are ways ACOs can leverage this information: 

  • Developing Post-Acute Care Strategies: By analyzing care episodes, ACOs can pinpoint areas for improvement in post-acute care utilization, potentially structuring risk contracts with care providers to elevate overall care quality and reduce costs. 
  • Refining Specialist Referrals: The data provides a new layer of transparency into the performance of hospitals and specialists, allowing ACOs to optimize referral patterns and engage in more informed specialist performance benchmarking. 
  • Preparing for Mandatory Bundles: Familiarity with shadow bundles can prepare organizations for future success under mandatory bundled payment initiatives by CMS, focusing on care improvements and cost reductions. 
  • Strategizing Hospital and Specialist Engagement: By understanding service line trends and quantifying the impact of referrals, ACOs can forge more effective partnerships and engage in performance-based negotiations with hospitals and specialists, aligning incentives towards shared goals of quality and cost efficiency. 

Challenges and Considerations 

While the potential benefits of leveraging shadow bundles are significant, ACOs must tread carefully. The data, though rich, does not encompass the entirety of specialist performance or patient care journeys. A comprehensive evaluation would require considering factors such as care provided outside of acute episodes, outpatient surgeries, and the entire pre- and post-surgery care continuum. Thus, ACOs must develop nuanced, sophisticated strategies for data analysis and application. 

Additionally, integrating insights from shadow bundles with broader organizational strategies necessitates robust data analytics capabilities. Organizations that can effectively parse, understand, and act upon the wealth of information provided will be better positioned to optimize care delivery and achieve cost efficiencies. 


The introduction of shadow bundles by CMS represents a forward-thinking approach to promoting transparency, accountability, and value-based care within the healthcare system. By providing ACOs with a detailed window into care episodes and related costs, CMS is not only equipping them with tools for immediate improvement but also preparing them for the future landscape of bundled payments. Success in this new era will require a blend of strategic foresight, analytical prowess, and organizational agility. 

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