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The Norfolk market is defined by high consolidation. The area’s most populous townships are separated by bodies of water, giving the market defined submarkets where health systems compete. Some payers and providers have chosen to conduct business to the north, while others stay mainly on the south side of the market, where Norfolk and Virginia Beach are. Much of the value-based care in the market revolves around the Medicare program and bundled payment activity, with little in commercial care coordination. This is likely because employers here have so far preferred full network PPOs, leading to the demise of a commercial ACO. Even the health plan owned by the market's largest health system covers most local health systems. This means commercial ACOs will have a tough time growing here unless Optima chooses to offer a much less expensive narrow network plan that entices employers on price.