Medicare payment models tested by the Center for Medicare and Medicaid Innovation (CMMI) cost the federal government $7.7 billion, which included $6.4 billion in model net expenses and $1.3 billion in model-specific implementation and evaluation costs. Of the 18 CMMI models analyzed by health care consulting firm Avalere Health Advisory, six yielded net savings of about $2.9 billion for the federal government. However, the savings were balanced by $9.6 billion in net losses generated by six models. The remaining six models had a nominal financial impact on Medicare costs.

CMMI, as established under the Patient Protection and Affordable Care Act (ACA), has broad, non-legislative authority to select, design, and test value-based payment models in Medicare, Medicaid, and the Children’s Health Insurance Program. Most models have focused on Medicare. The models are not required to be budget-neutral on initiation. After a model is active, CMMI monitors and evaluates the impact of the model to determine whether it meets the following goals:

• Improve the quality of care without increasing spending
• Reduce spending without reducing the quality of care
• Improve the quality of care and reduce spending compared what would have been spent under fee-for-service reimbursement

The models with the most significant savings during their performance periods were Maryland All Payer, Maryland Total Cost of Care, Accountable Health Communities, Pioneer Accountable Care Organizations (ACOs), Bundled Payments for Care Improvement Advanced, and Vermont All-Payer ACOs. The quality of care impacts for these models varied. Two decreased utilization, two had mixed results, one had no impact, and one had nominal improvements.

CMMI Models That Generated Savings
Model Name	Savings	Performance Years	Quality Of Care Impact
Maryland All Payer	$975 million	2014 to 2019	Decreased admissions and avoidable hospitalizations
Maryland Total Cost of Care	$689 million	2019 to 2025	Decreased admissions, readmissions, emergency department visits, and observation stays
Accountable Health Communities	$403 million	2017 to 2023	Mixed results: emergency department visits declined, but readmissions increased
Pioneer ACOs	$384 million	2012 to 2016	Nominal improvements in the quality of care measures for diabetes and cardiovascular disease
Bundled Payments for Care Improvement Advanced	$285 million	2018 to 2025	No statistical impact on quality performance
Vermont All-Payer ACOs	$186 million	2017 to 2025	Mixed results; it decreased acute care stays and specialty care visits, improved treatments for alcohol and other drugs, and achieved targets for addressing chronic conditions

The models with the most significant losses during their performance periods were Medicare Advantage Value-Based Insurance Design, Comprehensive Primary Care Plus, Primary Care First, Oncology Care Model, Bundled Payments for Care Improvement, and Part D Enhanced Medication Therapy Management. The quality of care impacts for these models varied. One resulted in improvements, three had mixed results, one had no impact, and one had nominal improvements.

CMMI Models That Generated Losses
Model Name	Losses	Performance Years	Quality Of Care Impact
Medicare Advantage Value-Based Insurance Design	$4.5 billion	2017 to 2025	Improved performance by increasing Medicare Advantage plan star ratings
Comprehensive Primary Care Plus	$2.8 billion	2017 to 2021	Mixed results on quality because emergency department visits and hospitalizations decreased, and there were small improvements across quality-of-care measures, but appropriate use of medications decreased
Primary Care First	$847 million	2021 to 2025	Mixed results on quality performance; preventable emergency department visits increased, but readmissions decreased
Oncology Care Model	$639 million	2016 to 2022	Nominal quality performance improvement in terms of a decrease in emergency department visits leading to a hospital stay
Bundled Payments for Care Improvement	$528 million	2013 to 2018	No statistical impact on quality performance
Part D Enhanced Medication Therapy Management	$289 million	2017 to 2021	Mixed results on quality performance; there was an increase in emergency department visits, outpatient visits, and opioid use; but a decrease in stays and length of stays; and lower adherence rates

The remaining six models had minimal financial impact on Medicare spending: Million Hearts Cardiovascular Disease Risk Reduction Model, Comprehensive Care for Joint Replacement Model, Next Generation ACOs, ESRD Treatment Choices Model, Comprehensive ESRD Care Model, and Comprehensive Primary Care. The quality of care impacts for these models varied. one resulted in improvements, two had mixed results, and two had no impact.

CMMI Models That Had Minimal Financial Impact
Model Name	Performance Years	Quality Of Care Impact
Million Hearts Cardiovascular Disease Risk Reduction Model	2017 to 2021	Mixed quality performance results in terms of a decrease in first-time heart attacks/strokes; increased hospitalizations; improved screenings and adherence
Comprehensive Care for Joint Replacement Model	2016 to 2024	Nominal performance improvement because it decreased elective surgery complications
Next Generation ACOs	2016 to 2021	No statistical impact on quality performance
ESRD Treatment Choices Model	2021 to 2025	No statistical impact on quality performance
Comprehensive ESRD Care Model	2015 to 2021	Improved performance by decreasing hospitalizations and catheter use; adherence also improved
Comprehensive Primary Care	2012 to 2016	Mixed results on quality performance in terms of a decrease in hospitalizations, emergency department visits, and primary care visits, but the likelihood of an emergency department visit increased

These findings were reported in Analysis Of CMMI Model Costs, Quality Performance, And Transparency by researchers with Avalere Health. The analysis focused on CMMI models with at least two years of model performance, at least two published evaluation reports, and affected over 25,000 beneficiaries or episodes of care. Avalere analyzed publicly available data and evaluation reports for each of the selected models as of December 2024. These sources included USA Spending for operational costs and the CMMI website for model information and evaluations. Avalere excluded Medicaid spending from this analysis.of model performance, at least two published evaluation reports, and affected over 25,000 beneficiaries or episodes of care. Avalere analyzed publicly available data and evaluation reports for each of the selected models as of December 2024. These sources included USA Spending for operational costs and the CMMI website for model information and evaluations. Avalere excluded Medicaid spending from this analysis.

In March 2025, the Center for Medicare and Medicaid Services (CMS) said it was ending four still-running CMMI models early: Primary Care First, End-Stage Renal Disease (ESRD) Treatment Choices, Making Care Primary, and Maryland Total Cost of Care. By ending these models early, CMS anticipates saving $750 million, based on published model evaluation reports and financial forecasting. The models will end by December 31, 2025. Additionally, two previously announced but not yet implemented models to reduce drug costs will not be pursued: Medicare $2 Drug List and Accelerating Clinical Evidence.

Avalere Health Advisory is part of Avalere Health, a global health care consulting firm. Avalere Health Advisory is focused on life sciences, health plans, provider organizations, and private equity investors in the health care space.

The full text of Analysis Of CMMI Model Costs, Quality Performance, And Transparency was published April 2, 2025, by Avalere Health. A free copy is available online at https://advisory.avalerehealth.com/wp-content/uploads/2025/04/Analysis-of-CMMI-Model-Costs-Quality-Performance-and-Transparency.pdf (accessed April 24, 2025).

For more information, contact: Marita Gomez, Public Relations Manager, Avalere Health, 1201 New York Avenue Northwest, Suite 1000, Washington, District of Columbia 20005; 202-207-1300; Email: marita.gomez@avalere.com; Website: https://avalere.com/contact

August 2025     00US25EUA0023