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