Shadow Bundles for ACO Success: Unlocking CMS’s Data Shift Leverage

The use of Shadow Bundles for ACO Success is a wake-up call as much as a new compliance tick. CMS changed the rules in December 2023 when it announced that all ACO REACH and Medicare Shared Savings Program (MSSP) participants will start receiving shadow bundle data in February 2024. This was not a gentle recommendation. It was a calculated move in the direction of CMS’s overarching 2030 objective, which is to establish accountable care relationships for all Original Medicare beneficiaries.

The purpose of this data transfer was not to introduce noise. It all came down to clarity, which would enable ACOs to take more decisive action, measure care in a meaningful way, and work with experts more successfully. ACOs should be able to view their aligned patient expenses, referral pathways, and results with shadow bundles and compare them to those of their national counterparts.

The problem now is that when the data is there, there is a chance to use it effectively.

What You Need To Know About Shadow Bundles

The phrase “shadow bundles” describes the episodic cost and utilization data that CMS releases. This data gives ACOs something, maybe more valuable visibility, even if it has no direct bearing on shared savings or change attribution technique.

What’s Included in the Shadow Bundle Dataset?

The three primary report formats that ACOs get are all related to the same episode categories that will be included in the next TEAM (Transforming Episode Accountability Model):

• Files at the monthly episode level
• Summary reports every three months
• Comparisons of benchmark prices per year

These cover two multi-setting episodes, three outpatient episodes, and 29 inpatient episodes. Together, they are responsible for 23% of the overall expenses of Medicare Parts A and B. This is not a small matter. These incidents affect many different areas of treatment, including infectious illness, neurology, and cardiac and pulmonary care.

The following summarizes the alignment between TEAM and shadow bundle episodes:

Episode Type	Included Conditions	Covered Settings
Inpatient	Cardiac, joint, GI, kidney, pulmonary	Hospital, post-acute
Outpatient	Cancer, cardiac imaging, and kidney-related	Ambulatory surgical centers
Multi-setting	Dialysis, sepsis	Cross-setting combinations

In addition to highlighting expenses, the dataset highlights variations in post-acute care patterns, specialist behavior, and patient migration across care facilities.

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Why This Matters Now

Although CMS has made no secret of its objectives, this is the first significant move to push episode responsibility outside of hospital systems. Hospitals will be subject to new payment arrangements as a result of the BPCI-A sunsetting and the impending TEAM. ACOs can get ready before the same amount of pressure hits them because of shadow bundles.

What Shadow Bundles Enable ACOs to Do

Previously secret information is now visible to ACOs. They can:

• Referral leakage and episode expenses broken down by institution or specialization
• Examine their results about the national averages.
• Create plans to keep expenses under control for the duration of the 90-day program.

Crucially, they may begin contract negotiations and partnership formation using authentic, clean data.

Actionable Ways ACOs Should Be Using Shadow Bundles

This is not a theory. Some Shadow Bundles for ACO Success are already in motion, and the dataset is already available. The following are useful tactics that astute companies are beginning to implement with shadow bundle intelligence.

1. Build Post-Acute Care (PAC) Protocols That Work

After discharge, the majority of ACOs have blind spots. By providing 90-day insights into what is occurring in PAC contexts, shadow bundles highlight that. There is potential to move toward increased home health, improved discharge planning, or strategic SNF partnerships if benchmarks indicate that an ACO uses SNFs at a higher rate than the norm.

2. Align Specialist Referrals With Cost and Quality Data

Sending patients to experts is not an excuse to continue to operate in the dark. ACOs can begin creating referral pathways that lessen volatility and increase predictability by comparing the average episodic expenses for particular diseases among providers using shadow bundle data.

3. Optimize Hospital Collaborations

This information is not only for internal use. It makes meaningful dialogues with healthcare systems possible. Based on those common goals, ACOs can negotiate with institutions that have better PAC transitions and lower rates of complications.

4. Strengthen Value-Based Contract Negotiations

Defensible data is important when negotiating with commercial payers or Medicare Advantage. Payers want ACOs to show cost-effectiveness across whole episodes of care when negotiating rates and bonuses, and shadow bundle reports allow them to do just that.

Role of Specialty Care Integration

Additionally, shadow bundles present a useful opportunity for more thorough specialist care integration, an area that has historically received little attention from ACOs.

Why Specialty Integration Is Crucial

• Specialists drive costs: Expert-driven choices have a significant impact on spending in episodic models.
• Referral patterns matter: Determining the areas of variance can influence patient selection.
• Bundled data offers leverage: ACOs acquire control over downstream care coordination with detailed episode cost comparisons.

Key Opportunities for Integration

• To encourage alignment with high-performing specialists, use episode performance data.
• Make shared savings models especially for episodes of the Shadow Bundle.
• Create care paths tailored to each disease using episodic data.

Don’t Ignore These Limitations

Although they might not cover everything, shadow bundles do open a door. It is important to understand their limitations.

• The representation of Medicare expenses is just 23%.
• Even at ambulatory surgical centers, many outpatient procedures could go unrecorded.
• The lack of tracking for pre-trigger event care renders chronic care coordination before admission undetectable.

For a more complete picture, ACOs should integrate total cost-of-care measures with information from shadow bundles. Having the appropriate technology partner becomes crucial at this point.

The Need for a Strong Digital Health Platform

ACOs require a strong Digital Health Platform that can perform risk stratification, integrate various data formats, and present actionable insights to use shadow bundle data efficiently.

Even the greatest shadow bundle of data ultimately goes unused in the absence of real-time dashboards, historical comparisons, and adjustable filters. To make sense of the data, the platform should also make population segmentation and performance assessment easier.

The Bigger Picture: Preparing for Mandatory Models

Shadow bundles are more than a supplementary dataset. For the upcoming 2026 mandated bundled payment models under TEAM, they are a calculated test run.

Organizations will be better equipped not only for compliance but for prospering under pressure if they take this phase seriously, develop skills now, and put what they learn into practice.

Takeaway

There is no speculation with shadow bundles. They are dynamic, real-time technologies that support ACOs in doing what they have always needed to do: more accurately and transparently manage care episodes.

Organizations are already strengthening their referral networks, enhancing care coordination, and negotiating better with payers when they view this data as an opportunity rather than a reporting burden.

In a field that is rapidly transitioning from voluntary to required accountability, failing to take action now might mean losing out on a significant advantage.

How Persivia Can Help

ACOs can confidently navigate shadow bundles with the help of Persivia CareSpace®. It provides advanced analytics that combine more general ACO performance measures with episode-level data. Persivia enables enterprises to manage care episodes with clarity and consistency with its robust digital platform’s benchmarking capabilities, intelligent population segmentation, and automation based on shadow bundle insights.