AAPM&R, in a collaborative effort with the American Medical Association (AMA), the National Association of Accountable Care Organizations (ACOs) and several other groups, signed on to a letter in late March to the Centers for Medicare & Medicaid Services (CMS) outlining recommendations in response to the agency’s Notice of Proposed Rulemaking that would modify the Medicare Shared Savings Program benchmarking methodology. The main focus of the proposal is to incorporate a portion of regional cost data into ACO benchmarks. This would help compare ACOs to their region rather than requiring them to continuously exceed their past performance, which over time becomes increasingly more difficult, even for the most efficient ACOs. Overall, your Academy supports the proposal to incorporate a component of regional cost data into ACO benchmarks, and the sign-on letter urges CMS to modify aspects of the proposed benchmarking methodology, among other changes.