Although 45% of ACOs now comprise physician groups without a hospital partnership, the market potential for further growth of physician group–led ACOs is much stronger than for hospital- or health system–led ACOs. Our market potential estimates are admittedly rough and should be viewed as only directionally correct, but they suggest that there is more room for physician-led ACOs to develop than for ACOs that include hospitals. The sheer number of physician groups suggests that the dominant type of provider moving forward that has the potential to bear risk will not be hospital based. Additionally, the Medicare Access and CHIP Reauthorization Act, which is targeted to physicians, may further the adoption of ACO models by physician groups so that they can avoid the Merit-based Incentive Payment System and potentially receive the additional 5% boost from participating in an advanced alternative payment model.