Does an ACO participant have to report MIPS?

Yes, ACO participants generally must report for the MIPS Promoting Interoperability (PI) performance category, even when their ACO reports group-level data. Starting in 2025, ACOs will continue to report quality data through the APP, but MIPS-eligible clinicians must also fulfill individual or TIN-level Promoting Interoperability (PI) requirements unless they qualify for an APM exemption.

Understanding MIPS Reporting for ACO Participants

Participation in an Accountable Care Organization (ACO) does not automatically exempt clinicians from the Merit-Based Incentive Payment System (MIPS).

The reporting requirements depend on:

• The ACO’s participation option (Basic vs. Enhanced track)

• Whether clinicians qualify as Qualifying Participants (QPs) under an Advanced APM

2025 clarification:

ACOs continue to report quality measures through the APP framework.  However,  Promoting Interoperability (PI) must still be fulfilled by MIPS-eligible clinicians at the individual or TIN level, unless an APM exemption applies.

Key Distinctions Between MIPS APM Participants and Advanced APM Participants

MIPS APM Participants (e.g., Basic Track Levels A–D)

• Must submit MIPS data, including PI measures.

• Receive a single MIPS score associated with the APM Entity, but PI obligations persist at the clinician or TIN level.

Advanced APM Participants (e.g., Basic Level E or Enhanced Track)

• May be exempt from MIPS if they meet CMS QP thresholds for patients or payments.

• Are assessed for payment adjustments under the APM track rather than standard MIPS.

Need to confirm your status? Use CMS’s APM Lookup Tool

MIPS Reporting Requirements for ACO Clinicians

For ACOs continuing under MIPS obligations:

• Promoting Interoperability (PI): Must be reported using 2015 Edition Certified EHR Technology (CEHRT) at the individual or TIN level, unless exempt or QP.

• APP Quality Submission: Continues at the ACO/APM Entity level using eCQMs or MIPS CQMs through an approved submission pathway.

• CMS Web Interface Sunset: Beginning with PY2025, the Web Interface is no longer available. ACOs must use a Qualified Registry or QCDR for APP submissions.

• TIN Responsibility: Each Tax Identification Number (TIN) within the ACO must coordinate PI measure submission or work with a qualified third-party vendor.

Exemption Paths: Qualifying Participant (QP) Status

Clinicians may avoid MIPS if their ACO meets Advanced APM thresholds and they achieve QP status by:

• Seeing at least 35% of Medicare Part B patients through the Advanced APM, or

• Receiving at least 50% of Medicare Part B payments through the Advanced APM.

These thresholds are calculated at the ACO level but applied to each individual clinician.

Why This Matters for ACO Participants

• Avoid penalties: Missing MIPS or PI obligations can trigger negative payment adjustments.

• Preserve incentives: Accurate reporting helps maintain eligibility for positive payment adjustments under the QPP.

• Reduce burden: Coordinated APP reporting and centralized PI workflows streamline data submission across TINs.

How Medisolv Helps

Navigating overlapping MIPS and ACO reporting can be complex — but Medisolv makes it easier.

Our APP Reporting Package:

• Aggregates Promoting Interoperability and quality measure data across multiple EHRs.

• Validates performance at both the APM Entity and individual clinician levels.

• Adapts to CMS changes, including the Web Interface sunset.

• Provides near-real-time dashboards that enable ACO participants to track MIPS scoring and stay compliant.

Learn More About MIPS and ACO Reporting

• How to Take the Leap into eCQMs for ACOs

• 2025 Quality Payment Program Overview

• 2025 APP Reporting Requirements for ACOs
• Medicare QPP: What it is, MIPS vs APMs, & How Medisolv Can Help