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ACCESS · ISSUE 080
cms-provider-data-catalogOriginal Research

Medicare's largest value-based program is a long tail with a heavy head

The Medicare Shared Savings Program looks broad — 511 accountable care organizations for 2026, holding 15,329 participant organizations. But its weight sits in a small head: the largest 10% of ACOs hold 43.5% of all participants, the smallest half just 11.8%, and the full-risk Enhanced track carries 71.0% of the network.

BY FONTEUM LLC · JUNE 16, 2026 · 8 MIN READREVIEWED BY DR. JENNIFER MONTECILLO, MDSNAPSHOT 2026-06-16 · LAST UPDATED JUNE 16, 2026
CMS Provider Data Catalog · 2026-06-16
Where the MSSP network's weight sits: participant organizations by ACO size, 2026cms-provider-data-catalog · 2026-06-16
ACOs of 61–120
4113
ACOs of 31–60
3560
ACOs of 121+
3554
ACOs of 16–30
2651
ACOs of 6–15
1137
ACOs of 1–5
314
Built on CMS Provider Data Catalog · snapshot 2026-06-16 · reproducible · re-derive the figures yourself
Key findings
of the 15,329 participant organizations on CMS's MSSP file sit in the largest 10% of accountable care organizations — 51 of the 511 ACOs. The largest 5% (26 ACOs) hold 29.7%, and the ten biggest ACOs alone hold 17.3%. The program is broad on paper and concentrated in practice
cms-provider-data-catalog · CMS
of all participant organizations belong to ACOs in the Enhanced track — CMS's full two-sided-risk model. Enhanced ACOs are 57.9% of ACOs by count but carry 71.0% of the network because they are larger: 36.8 participants on average against 20.7 for the lower-risk Basic track
cms-provider-data-catalog · CMS
is all the smaller half of the program holds: the 256 smallest ACOs share 11.8% of participant organizations. 125 ACOs (a quarter of the program) have five participants or fewer — 2.0% of the network between them — and 44 ACOs are a single participant organization
cms-provider-data-catalog · CMS
participant organizations sit in the single largest ACO, against a median ACO size of 17 and a mean of 30.0. The gap between median and mean is the signature of the long tail — most ACOs are small, a few are very large, and the average sits far above the middle
cms-provider-data-catalog · CMS
accountable care organizations make up the published PY2026 file, holding 15,329 participant organizations across 15,293 distinct legal business names, CMS release dated 2026-01-22. The public file carries no participant TIN or NPI, so every figure is a count at the ACO, track, or program level — no individual provider is named, ranked, or scored
cms-provider-data-catalog · CMS

Medicare runs its biggest bet on value-based care through the Medicare Shared Savings Program. Hundreds of accountable care organizations — groups of doctors, hospitals, and practices that agree to take joint responsibility for the cost and quality of a population of Medicare patients — enroll each year, and CMS publishes the roster: every legal entity participating in every ACO, by performance year. Read at a glance, the 2026 file looks like a wide, level field — 511 ACOs, 15,329 participant organizations. Read by size, it is the opposite of level. Most of the program's weight sits in a handful of very large organizations, and the small ACOs that make up half the count barely register.

The network is a long tail with a heavy head

The 511 ACOs are wildly unequal in size. The median ACO holds 17 participant organizations; the mean is 30.0 — pulled far above the middle by a small number of very large ACOs, the largest of which holds 822. When the mean sits almost double the median, the distribution has a long right tail, and counting the program by ACO hides where its weight actually is.

ACO size (participant orgs)ACOsParticipant orgsShare of network
1–51253142.0%
6–151091,1377.4%
16–301242,65117.3%
31–60873,56023.2%
61–120494,11326.8%
121+173,55423.2%

Source: CMS MSSP ACO Participants, ACOs grouped by participant-organization count, PY2026 (CMS release 2026-01-22).

The two ends tell the story. 125 ACOs — a quarter of the program — hold five participant organizations or fewer, and 2.0% of the network between them; 44 of those are a single participant organization. At the other end, 17 ACOs of 121-plus participants hold 23.2% of the network — as much as the 358 smallest ACOs combined. The program is broad in its count of ACOs and concentrated in where its providers actually sit.

An ACO participant list is a roster of who signed up, not a scorecard of how they performed. It records one fact — that a legal entity joined a Shared Savings Program ACO for 2026 — and says nothing about the cost, quality, or savings any organization delivered.

Concentration, computed directly

Rank the ACOs by size and the head of the distribution dominates: the largest 10% of ACOs — 51 of 511 — hold 43.5% of all 15,329 participant organizations. Narrow the lens further and the concentration tightens.

Slice of ACOsACOsShare of participant orgs
Largest 10%5143.5%
Largest 5%2629.7%
Largest 10 ACOs1017.3%
Smallest 50%25611.8%

Source: CMS MSSP ACO Participants, cumulative participant-organization share by ACO size rank, PY2026.

The smallest 256 ACOs — fully half the program — share 11.8% of participant organizations, roughly a quarter of what the largest 51 hold. This is the shape value-based care has taken: a small number of large, multi-state ACOs that aggregate hundreds of practices each, sitting above a long tail of small ACOs that carry a few participants apiece. Counting ACOs gives every organization one vote; counting participant organizations shows the program is run, in volume terms, by its head.

The full-risk track carries the network's weight

CMS runs the program on two risk models, and the riskier one holds most of the providers. The Basic track is a glide path with limited downside; the Enhanced track is the full two-sided-risk model, where an ACO can win a larger share of savings but is also liable for losses. Enhanced ACOs are a slim majority by count but a heavy majority by weight.

Risk trackACOsShare of ACOsParticipant orgsShare of networkMean size
Enhanced (full risk)29657.9%10,88571.0%36.8
Basic (glide path)21542.1%4,44429.0%20.7

Source: CMS MSSP ACO Participants, risk track by ACO, PY2026.

Enhanced ACOs are 57.9% of ACOs but hold 71.0% of all participant organizations, because they are larger on average — 36.8 participants against 20.7 in Basic. Risk and scale move together: the organizations willing to take full downside risk are also the ones large enough to spread it. The concentration in the first two sections is, in part, this — the heavy head of the distribution is disproportionately full-risk.

Revenue tier is not size

It would be easy to assume the large ACOs are simply the hospital-anchored, high-revenue ones. The file's revenue classification says otherwise. CMS labels each ACO high- or low-revenue by the ratio of its participants' Medicare revenue to its assigned-beneficiary spending — a structural marker of practice type, hospital-anchored versus physician-led, not of how many organizations an ACO contains.

Revenue tierACOsMean size
High-revenue18631.0
Low-revenue32529.4

Source: CMS MSSP ACO Participants, revenue tier by ACO, PY2026.

The two tiers' mean participant counts are nearly identical — 31.0 against 29.4 — so the concentration documented above is not a high-revenue artifact. Large ACOs are not simply the hospital systems; physician-led, low-revenue ACOs reach the head of the distribution too. Low-revenue ACOs are in fact the program's majority by count (325 of 511), a reminder that the Shared Savings Program is, organizationally, more physician-led than the hospital-ACO framing suggests.

What one row actually is

Each row in cms_mssp_aco_participants is one participant legal business name under one ACO for one performance year — a clinic, group practice, or facility that signed a participation agreement. The published CMS file carries no participant TIN and no NPI — those identifiers are restricted to ResDAC — so there is no individual-provider identifier in this data at all, and the NPI-to-entity-graph link is deferred: MSSP participation renders on no individual provider profile. Every figure in this study is a count at the ACO, risk-track, revenue-tier, or program level. No clinician and no individual organization is named, ranked, or scored, and the study draws no inference about any ACO's cost, quality, or shared-savings results.

Methodology

All figures are direct aggregations over the cms_mssp_aco_participants table, populated from the CMS Accountable Care Organizations (ACO Participants) public-use file published through the CMS data catalog (data.cms.gov, Medicare Shared Savings Program). The table holds 15,329 participant rows across 511 ACOs and 15,293 distinct legal business names; performance year 2026; CMS release dated 2026-01-22; public, read-only; license US-Government-Works. CMS publishes one ACO Participants file per performance year, so figures advance with each annual release.

This study reads the published file as a whole — every row is a participant CMS lists as enrolled in an MSSP ACO for PY2026. "ACO size" is the count of participant legal business names sharing an aco_id. The risk-track and revenue-tier splits use the file's own enhanced_track, basic_track, high_revenue_aco, and low_revenue_aco flags, taken at the ACO level (bool_or across an ACO's rows, which are internally consistent). Concentration figures rank ACOs by size and read the cumulative participant-organization share off the top. Because these are counts and ratios over a published file, every figure is exact as of the release rather than estimated. Methodology version: cms-mssp-aco/v1. The source-provenance contract is documented in the provenance methodology.

Limitations

  • A participation record, not a performance signal. MSSP participation records that a legal entity enrolled in a Shared Savings Program ACO. It is not a measure of shared savings achieved, spending against benchmark, clinical quality, or outcomes, and carries no endorsement. This study draws no inference about any ACO's results from the size or composition of its participant list.
  • Aggregate and ACO-level only. Every figure is a count or percentage at the ACO, risk-track, revenue-tier, or program level. No individual provider or organization is named, ranked, or scored. The public file carries no TIN or NPI, and the entity-graph link is deferred, so MSSP participation renders on no provider profile.
  • The unit is the participant organization, not the provider. One row is one legal business name under one ACO — a practice or facility, which may employ many clinicians or none directly. Counts of participant organizations are not counts of physicians, and an ACO's beneficiary population is not published in this file.
  • Single performance year. The file is the PY2026 roster. CMS republishes one ACO Participants file per year, so this study is a point-in-time cross-section, not a trend; it does not model entry, exit, or year-over-year change.
  • Service area is a CMS label, not a state key. Most ACOs span more than one state, and aco_service_area is frequently a multi-state string (242 of 281 labels). Geographic figures treat the field as a labelled characteristic; this study does not assign ACOs to single states or rank states by ACO presence.
  • Size is participant count, not assigned beneficiaries. "ACO size" here means the number of participant legal business names, the only size measure in the public file. It is a proxy for organizational scale, not for the number of Medicare patients an ACO is accountable for.

Sources

The companion dataset page for CMS MSSP ACO Participants lists the full schema and refresh cadence. This is the value-based-care mirror of who is enrolled to bill Medicare in the first place and of the March 2026 spike in Medicare enrollment deactivations; for where providers cluster thickest see Medicare market saturation, for who steps outside the program entirely the behavioral-health story of Medicare opt-outs, and for the enrollment machinery underneath it all the Medicare revalidation backlog and the coverage mix at America's community health centers.

Frequently asked questions

What is an ACO in the Medicare Shared Savings Program?
An accountable care organization (ACO) is a group of doctors, hospitals, and other providers that join together to take coordinated responsibility for the cost and quality of care for a defined population of Medicare patients. Under the Shared Savings Program, an ACO that keeps spending below a benchmark while meeting quality standards shares in the savings; in the higher-risk tracks it also shares in the losses. CMS publishes the list of legal entities participating in each ACO by performance year.
How concentrated is the Medicare Shared Savings Program?
Heavily, despite looking broad. The 2026 file lists 511 ACOs holding 15,329 participant organizations, but the largest 10% of ACOs (51 of them) hold 43.5% of all participant organizations, and the largest ten ACOs alone hold 17.3%. The smallest half of the program — 256 ACOs — holds just 11.8%. A quarter of all ACOs have five participants or fewer.
What is the difference between the Basic and Enhanced ACO tracks?
They are the program's two risk models. The Basic track is a glide path with limited or no downside risk, intended for newer or smaller ACOs; the Enhanced track is the full two-sided-risk model, where an ACO can earn a larger share of savings but is also liable for a larger share of losses. In the 2026 file, Enhanced ACOs are 57.9% of ACOs by count but hold 71.0% of all participant organizations, because they tend to be larger — 36.8 participants on average against 20.7 in Basic.
Does being in a large ACO mean a provider is better?
No. An ACO participant list records that a legal entity enrolled in a Shared Savings Program ACO for a given year — nothing more. It is not a measure of cost performance, shared savings achieved, clinical quality, or outcomes, and it carries no endorsement. This study counts how participation is distributed across ACOs; it draws no inference about any provider or any ACO's results.
Where are Medicare ACOs concentrated geographically?
The file's service-area field is a CMS label rather than a clean state key, and most ACOs span more than one state — 311 of the 511 carry a multi-state label. Among the single-state labels that recur, California, Florida, and Texas appear most often, the same large markets that anchor most Medicare provider geographies. Because the field is frequently multi-state, this study treats geography as a labelled characteristic, not a precise state ranking.
Can I reproduce these figures?
Yes. Every number is a direct count over the public cms_mssp_aco_participants table — CMS's MSSP Accountable Care Organizations (ACO Participants) file, performance year 2026, CMS release dated 2026-01-22 — with no modeling. The exact SQL for the size distribution, the concentration curve, the risk-track split, and the revenue-tier check is published in the reproducibility block below.

Who uses this data

The source data behind this study is public

Compliance teams, journalists, and researchers work from the same federal source families cited above — queried by NPI or facility identifier through Fonteum’s open dataset pages and API. Every figure traces to a frozen, downloadable snapshot you can reproduce yourself.

Reproducibility

Every claim, reproducible

The SQL
mssp-aco-participation-concentration-2026.sql
-- How concentrated is Medicare's largest value-based-care program? The Medicare
-- Shared Savings Program (MSSP) looks like a broad network — 511 accountable
-- care organizations (ACOs) for performance year 2026 — but its weight sits in
-- a small head. Fully reproducible query.
--
-- Question: across the published MSSP ACO Participants file, how are the 15,329
-- participant organizations distributed across the 511 ACOs, which risk track
-- and revenue tier do the large ACOs sit in, and how concentrated is the
-- network? The lead figure: the largest 10% of ACOs (51 of 511) hold 43.5% of
-- every participant organization on the file. MSSP participation is a
-- value-based-care program ENROLLMENT record — it is NOT a measure of an ACO's
-- shared-savings performance, cost, quality, or outcomes of any kind.
--
-- Source:
--   public.cms_mssp_aco_participants — CMS "Accountable Care Organizations"
--     (ACO Participants) public-use file, published annually via the CMS data
--     catalog (data.cms.gov, Medicare Shared Savings Program). 15,329
--     participant rows; 511 distinct ACOs; performance year 2026; CMS release
--     2026-01-22. Public, read-only. License: US-Government-Works (17 U.S.C.
--     Sec. 105). methodology_version = 'cms-mssp-aco/v1'.
--
-- Universe: this study reads the published file AS A WHOLE — every row is one
--   participant legal business name (LBN) that CMS lists as enrolled in an MSSP
--   ACO for PY2026. The public file carries NO participant TIN or NPI (those are
--   restricted to ResDAC), so there is no individual-provider identifier here;
--   the unit is the participant organization (LBN), not a person. No individual
--   provider is named, ranked, or scored. Counts are exact over the file.
--
-- Counting note: "participant organization" = one row (one LBN under one ACO).
--   "ACO size" = the count of participant LBNs in an ACO. 15,293 distinct LBNs
--   across 15,329 rows (a handful of LBNs appear under more than one ACO).

-- ============================================================================
-- (1) Universe reconciliation — the published file at a glance.
-- ============================================================================
SELECT
  count(*)                                                          AS participant_rows,
  count(DISTINCT aco_id)                                            AS acos,
  count(DISTINCT participant_lbn)                                   AS distinct_lbn,
  count(DISTINCT performance_year)                                  AS performance_years,
  max(performance_year)                                             AS performance_year,
  max(source_release_date)                                          AS cms_release,
  max(methodology_version)                                          AS methodology_version
FROM public.cms_mssp_aco_participants;
--  participant_rows 15,329 · acos 511 · distinct_lbn 15,293
--  performance_years 1 · performance_year 2026 · cms_release 2026-01-22
--  methodology_version cms-mssp-aco/v1

-- ============================================================================
-- (2) HEADLINE: ACO size distribution. Each ACO's size = its count of
--     participant organizations. The network is a long tail with a heavy head:
--     a quarter of ACOs (125) hold 5 participants or fewer — just 2.0% of the
--     network — while 17 ACOs of 121+ participants hold 23.2%.
-- ============================================================================
WITH sz AS (
  SELECT aco_id, count(*) AS p
  FROM public.cms_mssp_aco_participants
  GROUP BY aco_id
)
SELECT
  CASE
    WHEN p BETWEEN 1 AND 5    THEN '1-5'
    WHEN p BETWEEN 6 AND 15   THEN '6-15'
    WHEN p BETWEEN 16 AND 30  THEN '16-30'
    WHEN p BETWEEN 31 AND 60  THEN '31-60'
    WHEN p BETWEEN 61 AND 120 THEN '61-120'
    ELSE '121+'
  END                                                               AS size_band,
  count(*)                                                          AS acos,
  sum(p)                                                            AS participants,
  round(100.0 * sum(p) / (SELECT sum(p) FROM sz), 1)                AS pct_of_network
FROM sz
GROUP BY size_band
ORDER BY min(p);
--  1-5      125 acos ·   314 participants ·  2.0%
--  6-15     109 acos · 1,137 participants ·  7.4%
--  16-30    124 acos · 2,651 participants · 17.3%
--  31-60     87 acos · 3,560 participants · 23.2%
--  61-120    49 acos · 4,113 participants · 26.8%
--  121+      17 acos · 3,554 participants · 23.2%

-- ============================================================================
-- (3) Concentration, computed directly. Rank ACOs by size and read the
--     cumulative share off the top. The largest 10% of ACOs (51) hold 43.5% of
--     all participant organizations; the smallest half (256) hold 11.8%.
--     Median ACO = 17 participants, mean = 30.0, largest = 822, smallest = 1.
-- ============================================================================
WITH sz AS (
  SELECT aco_id, count(*) AS p FROM public.cms_mssp_aco_participants GROUP BY aco_id
), ranked AS (
  SELECT p, row_number() OVER (ORDER BY p DESC) AS rk, sum(p) OVER () AS tot
  FROM sz
)
SELECT
  (SELECT round(avg(p), 1) FROM sz)                                 AS mean_size,
  (SELECT percentile_cont(0.5) WITHIN GROUP (ORDER BY p) FROM sz)   AS median_size,
  (SELECT max(p) FROM sz)                                           AS largest_aco,
  (SELECT min(p) FROM sz)                                           AS smallest_aco,
  (SELECT count(*) FROM sz WHERE p = 1)                             AS single_participant_acos,
  (SELECT round(100.0 * sum(p) / max(tot), 1) FROM ranked WHERE rk <= 51)  AS top10pct_share,
  (SELECT round(100.0 * sum(p) / max(tot), 1) FROM ranked WHERE rk <= 26)  AS top5pct_share,
  (SELECT round(100.0 * sum(p) / max(tot), 1) FROM ranked WHERE rk <= 10)  AS top10_aco_share,
  (SELECT round(100.0 * sum(p) / max(tot), 1) FROM ranked WHERE rk > 255)  AS bottom50pct_share
FROM ranked
LIMIT 1;
--  mean_size 30.0 · median_size 17 · largest_aco 822 · smallest_aco 1
--  single_participant_acos 44
--  top10pct_share 43.5% (51 ACOs) · top5pct_share 29.7% (26 ACOs)
--  top10_aco_share 17.3% (10 ACOs) · bottom50pct_share 11.8% (256 ACOs)

-- ============================================================================
-- (4) The full-risk track carries the network's weight. CMS runs MSSP on two
--     risk models: BASIC (a glide path, lower downside risk) and ENHANCED (the
--     full two-sided-risk model). Enhanced ACOs are 57.9% of ACOs but hold
--     71.0% of all participant organizations, because they are larger on
--     average (36.8 participants vs 20.7 for Basic). Risk and scale move
--     together. These are mutually exclusive per ACO (296 + 215 = 511).
-- ============================================================================
WITH aco AS (
  SELECT aco_id, bool_or(enhanced_track) AS enhanced, count(*) AS p
  FROM public.cms_mssp_aco_participants
  GROUP BY aco_id
)
SELECT
  CASE WHEN enhanced THEN 'Enhanced (full risk)' ELSE 'Basic (glide path)' END AS track,
  count(*)                                                          AS acos,
  round(100.0 * count(*) / sum(count(*)) OVER (), 1)                AS pct_of_acos,
  sum(p)                                                            AS participants,
  round(100.0 * sum(p) / sum(sum(p)) OVER (), 1)                    AS pct_of_network,
  round(avg(p), 1)                                                  AS mean_size
FROM aco
GROUP BY enhanced
ORDER BY participants DESC;
--  Enhanced (full risk)  296 acos · 57.9% · 10,885 participants · 71.0% · mean 36.8
--  Basic (glide path)    215 acos · 42.1% ·  4,444 participants · 29.0% · mean 20.7

-- ============================================================================
-- (5) Revenue tier is NOT size. CMS classifies each ACO as HIGH- or
--     LOW-revenue by the ratio of its participants' Medicare revenue to its
--     assigned-beneficiary spending — a structural label about practice type
--     (hospital-anchored vs physician-led), not about how many organizations an
--     ACO contains. The two tiers' mean participant counts are nearly identical,
--     so the concentration in (2)-(4) is not a revenue-tier artifact.
-- ============================================================================
WITH aco AS (
  SELECT aco_id,
         bool_or(high_revenue_aco) AS high_rev,
         bool_or(low_revenue_aco)  AS low_rev,
         count(*) AS p
  FROM public.cms_mssp_aco_participants
  GROUP BY aco_id
)
SELECT
  count(*) FILTER (WHERE high_rev)                                  AS high_revenue_acos,
  round(avg(p) FILTER (WHERE high_rev), 1)                          AS high_rev_mean_size,
  count(*) FILTER (WHERE low_rev)                                   AS low_revenue_acos,
  round(avg(p) FILTER (WHERE low_rev), 1)                           AS low_rev_mean_size
FROM aco;
--  high_revenue_acos 186 · high_rev_mean_size 31.0
--  low_revenue_acos  325 · low_rev_mean_size  29.4

-- ============================================================================
-- (6) Service area is a CMS label, not a clean state key. Most ACOs operate
--     across more than one state, so aco_service_area is frequently a
--     multi-state string. Of 281 distinct service-area labels, 242 span more
--     than one state, and 311 of the 511 ACOs carry a multi-state label. The
--     single-state labels that recur most are CA, FL, and TX — the same large
--     markets that anchor most Medicare provider geographies.
-- ============================================================================
SELECT
  (SELECT count(DISTINCT aco_service_area) FROM public.cms_mssp_aco_participants)
                                                                    AS distinct_service_areas,
  (SELECT count(DISTINCT aco_service_area) FROM public.cms_mssp_aco_participants
     WHERE length(aco_service_area) > 2)                            AS multistate_labels,
  (SELECT count(DISTINCT aco_id) FROM public.cms_mssp_aco_participants
     WHERE length(aco_service_area) > 2)                            AS acos_multistate;
--  distinct_service_areas 281 · multistate_labels 242 · acos_multistate 311
--  single-state labels recurring most: CA 25 ACOs · FL 18 · TX 14 · PA 10 · NY 10
The snapshot
dataset_idcms-provider-data-catalog
snapshot_date2026-06-16
slsa_provenance_urlpending - publishes with the SLSA provenance generator (not yet live)
The JOINs
universe: the published file as a whole                                            -- 15,329 participant rows · 511 ACOs · 15,293 LBNs · PY2026 · CMS release 2026-01-22
ACO size = count of participant LBNs per aco_id                                     -- median 17 · mean 30.0 · largest 822 · smallest 1
size bands: GROUP BY CASE on participant count                                      -- 1-5: 125 ACOs / 2.0% ... 121+: 17 ACOs / 23.2%
concentration: rank ACOs by size, cumulative share off the top                       -- top 10% (51) = 43.5%; top 5% (26) = 29.7%; smallest 50% (256) = 11.8%
risk track = bool_or(enhanced_track) per ACO                                         -- Enhanced 296 ACOs (57.9%) hold 71.0% of network; mean 36.8 vs 20.7
revenue tier = bool_or(high/low_revenue_aco) per ACO                                 -- high 186 / mean 31.0; low 325 / mean 29.4 — tier is not size
service area is a CMS label, not a state key                                         -- 281 labels, 242 multi-state, 311 of 511 ACOs span >1 state
The pipeline version
git_sha8c06d24b
slsa_provenancepending - publishes with the SLSA provenance generator (not yet live)
methodology_versioncms-mssp-aco/v1

Reproduce this

Run the exact query against the frozen 2026-06-16.

-- How concentrated is Medicare's largest value-based-care program? The Medicare -- Shared Savings Program (MSSP) looks like a broad network — 511 accountable -- care organizations (ACOs) for performance year 2026 — but its weight sits in -- a small head. Fully reproducible query. -- -- Question: across the published MSSP ACO Participants file, how are the 15,329 -- participant organizations distributed across the 511 ACOs, which risk track -- and revenue tier do the large ACOs sit in, and how concentrated is the -- network? The lead figure: the largest 10% of ACOs (51 of 511) hold 43.5% of -- every participant organization on the file. MSSP participation is a -- value-based-care program ENROLLMENT record — it is NOT a measure of an ACO's -- shared-savings performance, cost, quality, or outcomes of any kind. -- -- Source: -- public.cms_mssp_aco_participants — CMS "Accountable Care Organizations" -- (ACO Participants) public-use file, published annually via the CMS data -- catalog (data.cms.gov, Medicare Shared Savings Program). 15,329 -- participant rows; 511 distinct ACOs; performance year 2026; CMS release -- 2026-01-22. Public, read-only. License: US-Government-Works (17 U.S.C. -- Sec. 105). methodology_version = 'cms-mssp-aco/v1'. -- -- Universe: this study reads the published file AS A WHOLE — every row is one -- participant legal business name (LBN) that CMS lists as enrolled in an MSSP -- ACO for PY2026. The public file carries NO participant TIN or NPI (those are -- restricted to ResDAC), so there is no individual-provider identifier here; -- the unit is the participant organization (LBN), not a person. No individual -- provider is named, ranked, or scored. Counts are exact over the file. -- -- Counting note: "participant organization" = one row (one LBN under one ACO). -- "ACO size" = the count of participant LBNs in an ACO. 15,293 distinct LBNs -- across 15,329 rows (a handful of LBNs appear under more than one ACO). -- ============================================================================ -- (1) Universe reconciliation — the published file at a glance. -- ============================================================================ SELECT count(*) AS participant_rows, count(DISTINCT aco_id) AS acos, count(DISTINCT participant_lbn) AS distinct_lbn, count(DISTINCT performance_year) AS performance_years, max(performance_year) AS performance_year, max(source_release_date) AS cms_release, max(methodology_version) AS methodology_version FROM public.cms_mssp_aco_participants; -- participant_rows 15,329 · acos 511 · distinct_lbn 15,293 -- performance_years 1 · performance_year 2026 · cms_release 2026-01-22 -- methodology_version cms-mssp-aco/v1 -- ============================================================================ -- (2) HEADLINE: ACO size distribution. Each ACO's size = its count of -- participant organizations. The network is a long tail with a heavy head: -- a quarter of ACOs (125) hold 5 participants or fewer — just 2.0% of the -- network — while 17 ACOs of 121+ participants hold 23.2%. -- ============================================================================ WITH sz AS ( SELECT aco_id, count(*) AS p FROM public.cms_mssp_aco_participants GROUP BY aco_id ) SELECT CASE WHEN p BETWEEN 1 AND 5 THEN '1-5' WHEN p BETWEEN 6 AND 15 THEN '6-15' WHEN p BETWEEN 16 AND 30 THEN '16-30' WHEN p BETWEEN 31 AND 60 THEN '31-60' WHEN p BETWEEN 61 AND 120 THEN '61-120' ELSE '121+' END AS size_band, count(*) AS acos, sum(p) AS participants, round(100.0 * sum(p) / (SELECT sum(p) FROM sz), 1) AS pct_of_network FROM sz GROUP BY size_band ORDER BY min(p); -- 1-5 125 acos · 314 participants · 2.0% -- 6-15 109 acos · 1,137 participants · 7.4% -- 16-30 124 acos · 2,651 participants · 17.3% -- 31-60 87 acos · 3,560 participants · 23.2% -- 61-120 49 acos · 4,113 participants · 26.8% -- 121+ 17 acos · 3,554 participants · 23.2% -- ============================================================================ -- (3) Concentration, computed directly. Rank ACOs by size and read the -- cumulative share off the top. The largest 10% of ACOs (51) hold 43.5% of -- all participant organizations; the smallest half (256) hold 11.8%. -- Median ACO = 17 participants, mean = 30.0, largest = 822, smallest = 1. -- ============================================================================ WITH sz AS ( SELECT aco_id, count(*) AS p FROM public.cms_mssp_aco_participants GROUP BY aco_id ), ranked AS ( SELECT p, row_number() OVER (ORDER BY p DESC) AS rk, sum(p) OVER () AS tot FROM sz ) SELECT (SELECT round(avg(p), 1) FROM sz) AS mean_size, (SELECT percentile_cont(0.5) WITHIN GROUP (ORDER BY p) FROM sz) AS median_size, (SELECT max(p) FROM sz) AS largest_aco, (SELECT min(p) FROM sz) AS smallest_aco, (SELECT count(*) FROM sz WHERE p = 1) AS single_participant_acos, (SELECT round(100.0 * sum(p) / max(tot), 1) FROM ranked WHERE rk <= 51) AS top10pct_share, (SELECT round(100.0 * sum(p) / max(tot), 1) FROM ranked WHERE rk <= 26) AS top5pct_share, (SELECT round(100.0 * sum(p) / max(tot), 1) FROM ranked WHERE rk <= 10) AS top10_aco_share, (SELECT round(100.0 * sum(p) / max(tot), 1) FROM ranked WHERE rk > 255) AS bottom50pct_share FROM ranked LIMIT 1; -- mean_size 30.0 · median_size 17 · largest_aco 822 · smallest_aco 1 -- single_participant_acos 44 -- top10pct_share 43.5% (51 ACOs) · top5pct_share 29.7% (26 ACOs) -- top10_aco_share 17.3% (10 ACOs) · bottom50pct_share 11.8% (256 ACOs) -- ============================================================================ -- (4) The full-risk track carries the network's weight. CMS runs MSSP on two -- risk models: BASIC (a glide path, lower downside risk) and ENHANCED (the -- full two-sided-risk model). Enhanced ACOs are 57.9% of ACOs but hold -- 71.0% of all participant organizations, because they are larger on -- average (36.8 participants vs 20.7 for Basic). Risk and scale move -- together. These are mutually exclusive per ACO (296 + 215 = 511). -- ============================================================================ WITH aco AS ( SELECT aco_id, bool_or(enhanced_track) AS enhanced, count(*) AS p FROM public.cms_mssp_aco_participants GROUP BY aco_id ) SELECT CASE WHEN enhanced THEN 'Enhanced (full risk)' ELSE 'Basic (glide path)' END AS track, count(*) AS acos, round(100.0 * count(*) / sum(count(*)) OVER (), 1) AS pct_of_acos, sum(p) AS participants, round(100.0 * sum(p) / sum(sum(p)) OVER (), 1) AS pct_of_network, round(avg(p), 1) AS mean_size FROM aco GROUP BY enhanced ORDER BY participants DESC; -- Enhanced (full risk) 296 acos · 57.9% · 10,885 participants · 71.0% · mean 36.8 -- Basic (glide path) 215 acos · 42.1% · 4,444 participants · 29.0% · mean 20.7 -- ============================================================================ -- (5) Revenue tier is NOT size. CMS classifies each ACO as HIGH- or -- LOW-revenue by the ratio of its participants' Medicare revenue to its -- assigned-beneficiary spending — a structural label about practice type -- (hospital-anchored vs physician-led), not about how many organizations an -- ACO contains. The two tiers' mean participant counts are nearly identical, -- so the concentration in (2)-(4) is not a revenue-tier artifact. -- ============================================================================ WITH aco AS ( SELECT aco_id, bool_or(high_revenue_aco) AS high_rev, bool_or(low_revenue_aco) AS low_rev, count(*) AS p FROM public.cms_mssp_aco_participants GROUP BY aco_id ) SELECT count(*) FILTER (WHERE high_rev) AS high_revenue_acos, round(avg(p) FILTER (WHERE high_rev), 1) AS high_rev_mean_size, count(*) FILTER (WHERE low_rev) AS low_revenue_acos, round(avg(p) FILTER (WHERE low_rev), 1) AS low_rev_mean_size FROM aco; -- high_revenue_acos 186 · high_rev_mean_size 31.0 -- low_revenue_acos 325 · low_rev_mean_size 29.4 -- ============================================================================ -- (6) Service area is a CMS label, not a clean state key. Most ACOs operate -- across more than one state, so aco_service_area is frequently a -- multi-state string. Of 281 distinct service-area labels, 242 span more -- than one state, and 311 of the 511 ACOs carry a multi-state label. The -- single-state labels that recur most are CA, FL, and TX — the same large -- markets that anchor most Medicare provider geographies. -- ============================================================================ SELECT (SELECT count(DISTINCT aco_service_area) FROM public.cms_mssp_aco_participants) AS distinct_service_areas, (SELECT count(DISTINCT aco_service_area) FROM public.cms_mssp_aco_participants WHERE length(aco_service_area) > 2) AS multistate_labels, (SELECT count(DISTINCT aco_id) FROM public.cms_mssp_aco_participants WHERE length(aco_service_area) > 2) AS acos_multistate; -- distinct_service_areas 281 · multistate_labels 242 · acos_multistate 311 -- single-state labels recurring most: CA 25 ACOs · FL 18 · TX 14 · PA 10 · NY 10

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Fonteum Research Bureau (2026). Medicare's largest value-based program is a long tail with a heavy head. CMS Provider Data Catalog, snapshot 2026-06-16. https://fonteum.com/research/mssp-aco-participation-concentration-2026

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  1. CMS Provider Data Catalog · snapshot 2026-06-16 · federal source family · US-Government-Works

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Platform snapshot · 2026-08-14

13.4Mproviders & companiesProviders, organizations, owners, and facilities on file
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