Background 

Medicare beneficiaries can choose to enroll in traditional fee-for-service (FFS) Medicare or in a Medicare Advantage (MA) plan. Under traditional FFS, providers are paid separately for each service or procedure performed with little to no incentives to promote coordination of care across healthcare providers. Meanwhile, MA plan sponsors receive a capitated monthly payment per enrollee, incentivizing plans to minimize costs and coordinate care. Providers in MA networks are often rewarded for keeping patients healthy and avoiding unnecessary hospitalizations or procedures.  

Accountable Care Organizations (ACOs) and ACO-like models are one approach used within the Medicare FFS population to support care management and coordination. They were introduced as part of efforts to reform traditional Medicare FFS. An ACO consists of a group of doctors, hospitals, and other healthcare providers that work together to coordinate patients’ healthcare to improve efficiency and health outcomes. Under ACO contracts, providers are paid normally under FFS, but have the opportunity to earn shared savings if they spend less than their benchmark and meets certain quality metrics (and conversely shared risk if spending exceeds benchmarks).    

In May 2025, the Center for Medicare and Medicaid Innovation  reported the estimated impact of ACOs on healthcare utilization in a report on the ACO Realizing Equity, Access, and Community Health (REACH) model. Under the model, some ACOs showed improvements in select areas like diabetes care, which could be due to the ACO’s efforts to increase primary care touchpoints and disease management.  

Results 

Avalere Health conducted an analysis of Medicare FFS claims in 2021 and found that, of the top 100 billing codes used in primary care offices, 48% of claims were for evaluation and management visits, annual wellness visits, or the initial “Welcome to Medicare” visit. On average, each enrolled beneficiary had 1.64 primary care touchpoints in 2021.  

A separate Avalere Health analysis focused on Medicare FFS beneficiaries assigned to an ACO in six select geographic markets with at least one evaluation and management visit had 11.1 care touchpoints per year in 2019 and 2021. These included an average of 4.1 visits with primary care physicians, 4.9 visits with specialists, and two visits with advanced practice providers.  

Among beneficiaries aligned to ACOs, those who visit their doctor at least once per year tend to have more frequent interactions with the healthcare system and appear to be more actively managing their conditions through regular visits.  

Data Source 

This analysis utilized the 100% Medicare FFS claims, accessed by Avalere Health via a research collaboration with Inovalon, Inc. and governed by a research-focused CMS Data Use Agreement. Avalere Health identified a sample of patients from 2019 and 2021 (2020 was excluded due to COVID-19).