If they are enrolled with Medicare and Medicaid and DO not have EHR when time comes, they would be quite foolish. The reductions would surely hurt them. Are you sure they are ACO certified? According to the Centers for Medicare and Medicaid Services (CMS), an ACO is "an organization of health care providers that agrees to be accountable for the quality, cost, and overall care of Medicare beneficiaries who are enrolled in the traditional fee-for-service program who are assigned to it."
They have agreements with CMS so if they have no plans to comply with EHR or meaningful use, they certainly might have some problems.