Medicare Shared Savings Program: Why Accurate Documentation and Coding Matter More Than Ever

The Medicare Shared Savings Program continues to be one of the most important value-based care initiatives in Medicare. As healthcare moves away from simply billing for visits and toward measuring outcomes, quality, care coordination, and cost efficiency, practices must be prepared to support the care they provide with accurate documentation and appropriate coding.

For independent practices, rural health clinics, specialty practices, and organizations participating in or supporting Accountable Care Organizations, this is no longer just a billing conversation. It is a revenue cycle, compliance, quality reporting, and operational performance conversation.


What Is the Medicare Shared Savings Program?


The Medicare Shared Savings Program, often referred to as MSSP, is a voluntary program through the Centers for Medicare & Medicaid Services that allows groups of physicians, hospitals, and other healthcare providers to form Accountable Care Organizations. These ACOs work together to coordinate care for Medicare fee-for-service beneficiaries. The goal is to improve quality of care, reduce unnecessary spending, and create accountability for the total cost and quality of care delivered to a defined Medicare population.

When an ACO meets quality standards and keeps Medicare spending below its benchmark, it may be eligible to share in the savings. CMS explains that savings are determined by comparing the ACO’s risk-adjusted Medicare expenditures against its updated benchmark. If spending is lower than the benchmark and meets the minimum savings rate, the ACO may qualify for shared savings.

Participation in this model continues to grow. For Performance Year 2026, CMS approved 134 Shared Savings Program applications, including 72 new ACOs and 62 renewing or reentering ACOs. That brings total Medicare Shared Savings Program participation to 511 ACOs for 2026, up from 476 in 2025.


Why Documentation and Coding Are So Important


In fee-for-service billing, documentation supports the claim. In value-based care, documentation supports the bigger picture: patient risk, chronic disease burden, quality performance, care gaps, preventive services, and medical necessity.

That means missed diagnoses, vague documentation, incomplete histories, or unsupported codes can create downstream problems. A condition that is not documented clearly may not be captured correctly. A preventive service that is not tracked properly may not support quality reporting. A chronic condition that is not addressed in the note may not accurately reflect the complexity of the patient population being managed.

In the Shared Savings Program, this matters because performance is not based only on whether a claim was paid. It is tied to whether the organization can demonstrate quality, accountability, and cost-effective care across a Medicare population.

Beginning in Performance Year 2025, CMS requires Shared Savings Program ACOs to report quality data using the Alternative Payment Model Performance Pathway Plus quality measure set, also known as the APP Plus measure set, to meet the quality performance standard used in determining shared savings and shared losses. For Performance Year 2026, CMS states that Shared Savings Program ACOs must report the quality measures included in the APP Plus quality measure set.

This makes accurate clinical data, structured documentation, and reliable reporting workflows essential.


Where EHR Workflow Comes Into Play


A complete EHR is more than an electronic filing cabinet. It should support the full clinical and financial workflow, from scheduling and documentation to coding, claim submission, reporting, and follow-up.

Azalea Health describes its platform as a cloud-based EHR and billing solution designed for rural hospitals, rural healthcare clinics, ambulatory practices, and specialty clinics. Its platform integrates clinical, billing, and operational workflows in one system to help practices reduce administrative overhead and operate more efficiently.

That connection between clinical documentation and billing is critical. If providers document in one place, billers code from another, and quality reporting lives somewhere else, it becomes much easier for important details to fall through the cracks.

A connected EHR workflow can help practices:

  • Capture chronic conditions more consistently.
  • Support accurate ICD-10-CM and CPT code selection.
  • Track preventive care and care gaps.
  • Improve documentation before the claim is submitted.
  • Reduce rework caused by incomplete notes.
  • Support cleaner claims and better audit readiness.
  • Give billing teams better visibility into the clinical story behind the encounter.

Azalea has also emphasized that accurate, timely clinical notes support correct coding and billing, while incomplete or inconsistent documentation can lead to claim delays, denials, and revenue cycle bottlenecks.


The Real-World Impact for Practices


For many practices, the issue is not that providers are failing to deliver quality care. The issue is that the documentation does not always tell the full story.

That gap matters.

For example, if a Medicare patient has diabetes, hypertension, chronic kidney disease, obesity, depression, or other chronic conditions, those diagnoses need to be documented clearly when they are assessed, monitored, evaluated, or treated. The documentation should support the medical decision-making and the codes submitted.

Likewise, preventive services, screenings, medication reviews, care coordination, and follow-up planning should be captured in a way that supports both patient care and reporting requirements.

In a value-based care environment, coding is not about “adding more codes.” It is about submitting the correct codes that accurately reflect the patient’s condition, the provider’s work, and the care being managed.


How Sunrise Services Can Help


At Sunrise Services, we understand that successful revenue cycle management starts long before the claim goes out the door. It starts with workflow, documentation, coding accuracy, system setup, and staff education.

With nearly 30 years of experience in medical billing and revenue cycle management, our team helps practices identify where revenue may be slipping through the cracks and where documentation or coding workflows need to be strengthened.

For practices using Azalea, we can help connect the operational dots between the EHR, coding, billing, denial prevention, and reporting. That includes reviewing documentation patterns, identifying missed coding opportunities, improving claim workflow, and helping staff use the system more effectively.

The Medicare Shared Savings Program is a strong reminder that the future of healthcare reimbursement is tied to value, data, and documentation. Practices that invest in cleaner workflows now will be better positioned for compliance, reporting, reimbursement, and long-term financial stability.


Final Thoughts


The Medicare Shared Savings Program is not just an ACO initiative. It reflects the broader direction of healthcare reimbursement.

Quality matters. Cost matters. Documentation matters. Coding matters.

And the practices that bring all of those pieces together through strong EHR workflows and experienced revenue cycle support will be in a better position to succeed.

If your practice is participating in value-based care, working with an ACO, or simply trying to improve coding accuracy and revenue cycle performance, now is the time to review your process.

Sunrise Services can help your team evaluate your documentation, coding, billing, and Azalea workflows to make sure the care you provide is supported by the codes you submit.


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