The Centers for Medicare & Medicaid Services (CMS) plans to expand quality reporting measures for Accountable Care Organizations participating in the Medicare Shared Savings Program through the APP Plus quality measure set beginning in performance year 2026. This article explores those changes to help ACOs get ready for performance year 2025 and beyond.
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In the ever-evolving landscape of healthcare policy, the Centers for Medicare and Medicaid Services is raising the stakes for Accountable Care Organizations. Starting in 2025, ACOs participating in the Medicare Shared Savings Program must report on an expanding set of quality measures under the Alternative Payment Model Performance Pathway Plus quality set (APP Plus).
This move underscores a growing recognition that quality and accountability are not just buzzwords but essential components of effective patient care. A greater emphasis on comprehensive data reporting could enhance care coordination and improve patient outcomes while shifting financial incentives toward value rather than volume.
In this article, we delve into what this mandate means for healthcare providers and patients alike, exploring the potential impacts on care delivery and financial performance of ACOs.
CMS is mandating Medicare Shared Savings Program Accountable Care Organizations (MSSP ACOs) to report the APP Plus quality measure set, expanding the number of quality measures these organizations will need to track beginning in 2025.
Under this new plan, as revealed in the recently released Physician Fee Schedule (PFS) final rule, MSSP ACOs that currently report using the APP quality measure set will continue reporting Medicare CQMs and Merit-based Incentive Payment System (MIPS) quality measure data in performance year (PY) 2025. However, reporting requirements for MSSP ACOs will progressively grow to 11 total measures in PY 2028 under APP Plus.
This initiative aligns with CMS’s overarching goal of leveraging the Adult Universal Foundation of quality measures, ensuring greater consistency across various CMS programs and initiatives.
The adopted changes aim to enhance alignment between MSSP ACOs and existing Medicare Core Sets, and the Marketplace Quality Rating System, both of which have incorporated quality measures from the Adult Universal Foundation. Additionally, there is an emphasis on harmonizing these metrics with those reported under the Value in Primary Care MIPS Value Pathway (MVP).
However, acknowledging potential challenges for some ACOs due to increased reporting requirements—particularly for those utilizing the CMS Web Interface collection type—the agency plans a phased approach for the APP Plus quality measure set between 2025 and 2028 to help mitigate burdens associated with these adjustments.
Despite the additional strain this may place on some organizations, CMS contends that this expanded measure set has potential benefits that could arise from scoring more extensive metrics.
For instance, with an increase in the number of reported measures, each individual measure would hold reduced weight in determining an ACO’s MIPS Quality overall performance category score—dropping from roughly 16.67 percent per six-measure set to approximately 12.5 percent per eight-measure set, according to the final rule.
These adjustments are part of broader efforts detailed in the recently released PFS final rule, which aim to refine how care is delivered under federal programs while enhancing patient outcomes through standardized measurement practices.
According to the PFS final rule, ACOs will see an increase in reporting requirements starting with performance year 2026. Six total measures will remain in 2025, and will increase to eight measures in 2026, nine measures in 2027, and 11 measures in performance year 2028.
Accordingly, expect the following new set of APP Plus quality measures in the coming years:
CMS has received widespread support for its commitment to implement the APP Plus quality measure set starting in 2025.
During the public comment period, which closed on September 9, some stakeholders praised this initiative as a vital step toward streamlining quality measure reporting across multiple programs, which is expected to alleviate the current burdens associated with monitoring, collecting, and submitting data.
In addition to facilitating improved efficiency in reporting processes, supporters believe the APP Plus requirements will encourage greater participation among ACOs, particularly those focused on serving underserved populations.
While some dissenting voices raised concerns about potential challenges ACOs may face due to these new requirements—citing existing resource constraints—many stakeholders agreed with the overarching goal of optimizing quality measurement frameworks within CMS programs. One commenter highlighted that by reducing administrative burdens related to reporting requirements, ACOs can redirect their efforts toward patient care initiatives and community outreach strategies.
CMS officials remain optimistic that implementing these changes will enhance quality assurance and improve healthcare experiences for all patients, not just Medicare beneficiaries. Agency leaders also hope to advance interoperability among providers while promoting population health and health equity by aligning with a standardized set of measures outlined in the Adult Universal Foundation measure set.
The agency believes that standardizing quality metrics across various initiatives will streamline healthcare providers’ operations and provide clearer insights into performance outcomes over time.
Meanwhile, CMS is finalizing policies to address concerns related to increased reporting burdens and to encourage ACOs to report the APP Plus quality measure set. These policies include:
Additionally, CMS confirms several changes as initially proposed:
In the final rule documents, CMS recognized the challenges that ACOs face in gathering data from small and specialty practices utilizing different electronic health records systems.
In recognition of this, for the performance year 2024 and beyond, CMS has established Medicare CQM collection types as a “transitional reporting option” specifically for MSSP ACOs. This option aims to provide greater flexibility and support in data reporting.
CMS also stated that it will monitor situations where small or specialty practices struggle with transitioning and reporting eCQMs and may make necessary adjustments in future rulemaking to help alleviate these issues.
As ACOs brace for the impending APP Plus quality measure reporting mandates from CMS, proactive preparation can set them apart and enhance their compliance outcomes.
Implementing robust data analytics solutions like MeasureAble™ can streamline their readiness by enabling ACOs to gather, analyze, and report performance data swiftly. This paves the way for identifying care gaps and benchmarking against industry standards, ensuring that ACOs are meeting requirements and excelling in quality healthcare delivery.
Are you part of an ACO striving to maximize your incentives in the Medicare Shared Savings Program? Speak with a Quality Expert today.
Would you like to learn more about this topic? We invite you to read the following related stories:
APP Reporting : What MSSP ACOs Should Know for 2025
How to Streamline MIPS Reporting and Boost Quality, Unlocking ACO Success
From Analytics to Action: How Modern Data Ecosystems Are Shaping Healthcare
