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Statement from Nicole Bradberry, CEO of FLAACOs & TXAACOs
FLAACOs and TXAACOs commend the Centers for Medicare & Medicaid Services (CMS) for addressing critical issues in the CY 2026 Medicare Physician Fee Schedule, including excessive and abusive billing practices that continue to undermine the financial stability of high-performing ACOs.
In both Florida and Texas, ACOs have taken proactive steps to identify and report suspect billing—particularly related to skin substitutes, wound care, and select Part B drugs. These services have triggered millions in inappropriate expenditures that, under current policy, ACOs are unfairly held accountable for. We support CMS’s proposal to reform payment policies for skin substitutes and encourage the agency to go further in shielding ACOs from the financial impact of anomalous claims that do not reflect the care delivered by our participating providers.
Our members are eager to work in partnership with CMS to improve fraud detection protocols and create mechanisms to hold bad actors accountable—without penalizing ACOs that are operating with integrity and delivering measurable improvements in care quality.
As Dr. Lori Lane, DPM, Certified Wound Care Specialist and Medical Director of Palm Beach ACO, shared:
“Ethically, [clinicians] should choose the least expensive, most effective product, but in a physician’s opinion, one product may work better than another. CMS failed in this situation because there were no restrictions or guidelines around these particular codes/products for a significant amount of time, and it led to abuse. Because it was easy to do.”
Florida and Texas continue to be national leaders in accountable care. Florida’s top ACOs, including Bluestone and Baptist Physician Partners, generated more than $64 million in combined gross savings in 2024. In Texas, Baylor Quality Health Care Alliance led with $107.6 million in savings, while Houston Methodist Coordinated Care and Elite Patient Care produced an additional $100 million combined. These outcomes reflect the strength of coordinated, physician-led care—and the importance of ensuring fair and sustainable policy frameworks moving forward.
FLAACOs and TXAACOs remain committed to supporting our ACO members as they navigate evolving regulations, adopt new payment models, and lead the charge in reducing unnecessary costs while improving patient outcomes. We appreciate CMS’s efforts and look forward to continued collaboration.
As we look ahead to 2026, FLAACOs and TXAACOs remain committed to advancing policies that support ethical, high-quality care delivery and protect the integrity of value-based models. We call on CMS to work more closely with ACO leaders to ensure payment reforms reflect the realities on the ground—and to hold bad actors accountable without punishing those doing the right thing.
We will continue to advocate for our members, elevate their voices, and collaborate with national partners to drive change where it’s most needed.
To learn more or to get involved in our advocacy efforts, contact us at [info@flaacos.com] or [info@txaacos.com].
Nicole Bradberry