Author: Kelly Conroy


Author: Zach Maher, MBA


Author: Daniela Bolivar, MHA
Senior Consultant


(303) 801-0111

The Centers for Medicare and Medicaid Services finalized changes to the 2023 ACO application cycle steps and timelines. After collectively submitting 50+ successful applications, Pinnacle is excited to continue interpreting the ever-changing ACO policy and execute future applications with the learned lessons and best practices gathered over the years. Here are some of the major highlights of the changes:

  • The Notice of Intent to Apply (NOIA) has been eliminated. Typically, in the past applicants had to submit an NOIA around the first week of June. CMS eliminated this step and moved up Phase 1 of the application. Let Pinnacle help you jump right into Phase 1 of the ACO application.
  • Phase 1 Submission starts in MAY. Thought you had a short window to recruit physicians before? Looks like it’s even shorter now. Phase 1 submission starts on May 18, 2023. In previous years, Pinnacle recommended starting recruitment in March or April, but suggests starting earlier. Time flies when you’re starting up ACOs.
  • ACOs will receive immediate beneficiary assignment estimates. This is one of the best enhancements to the process CMS could have made. In previous years, ACOs had to wait for Phase 1 RFI-1 as the first time they received a beneficiary assignment estimate. Then, you would get a second estimate during Phase 1 RFI-2, which was unfortunate, because if you did not meet the 5,000 beneficiary minimum, you could no longer add participants and your application would be denied.
  • Advance Investment Payments (AIP). ACOs that are interested in receiving AIPs will need to complete supplemental application materials as part of their initial application during Phase 2. If you are submitting a renewal application, you cannot apply for AIPs. ACOs will not receive their AIP eligibility final disposition until October 18.


Starting a new ACO? Want CMS to cover start up and infrastructure costs? Let Pinnacle help you with your AIP supplemental application materials.


Important dates to keep in mind:

  • May 18: ACO Application Begins – Make sure you start working on registering on the ACO Management System Portal to begin your application!
  • August 1: This is the final opportunity to add ACO participants and/or SNF affiliate TINs
  • September 5: This is the final opportunity to withdraw ACO participants and/or SNF affiliate TINs


Let us help you navigate the ACO application process and toolkit along with all of its changes. For more information, visit us online at or contact:


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