CMS Innovation Center Director Abe Sutton and CMS Administrator Dr. Mehmet Oz reaffirmed the administration's commitment to mandatory value-based models, targeting poor-performing providers for enrollment into alternative payment arrangements. This is a policy acceleration: the Biden CMMI favored voluntary pilots; Trump's CMMI is now pivoting toward forced accountability through mandatory participation, particularly for low-performing hospital systems and medical groups.

Mandatory models carry high operational stakes. CMMI has tested capitated payment arrangements (Global and Professional Direct Contracting, CJR, Oncology Care Model), but compliance burden, financial risk concentration, and data infrastructure requirements are steep. Practices already operating under merit-based incentive programs (MIPS) and quality reporting burdens face additional mandatory model enrollment if flagged for poor performance on cost, quality, or utilization metrics. A hospital system hitting readmission penalties or high cost-per-beneficiary could be forced into a full-risk capitation model within 18 months. Dental practices linked to medical groups will inherit the compliance tail.

Healthcare executives should stress-test cost and quality metrics now against CMMI benchmarks (CMS publishes provider-level performance data quarterly). Investment in clinical documentation, EHR/PMS interoperability, and predictive analytics is no longer optional—it's survival infrastructure. DSOs and larger group practices need governance structures (risk committees, actuarial support, network management) to operate in mandatory models. Smaller practices should consider affiliation or merger to spread mandatory model risk across larger entity.

CMMI will announce initial cohort of mandatory models Q3 2026; implementation Q1 2027. Watch for CMS letter to targeted providers by August 2026.