As proposed, the Medicare Shared Savings Program permits non-providers to hold up to a 25 percent interest in an ACO, thus allowing private investors in on the game. The shared savings payments, if any, still would go to the ACO, and it would be up to the ACO's governing body to determine allocation among participants, including investors. Under the social impact bond model, however, the full payment would go to the investor, creating a greater incentive for the investor to provide necessary capital.