How to Participate in Quality Reporting as an ACO
Quality reporting requirements for Accountable Care Organizations have shifted significantly. The transition away from the outdated CMS Web Interface and toward electronic clinical quality measures represents one of the biggest changes ACOs have navigated in years. If your ACO hasn't fully prepared for 2026 requirements, the stakes are real—failing to meet quality reporting obligations directly affects your organization's eligibility for shared savings.
This guide walks you through exactly what your ACO needs to do to stay compliant, optimize performance, and capitalize on shared savings opportunities under the Alternative Payment Model Performance Pathway (APP).
The Shift from GPRO to APP
Until 2024, ACOs could report through the Group Practice Reporting Option (GPRO) Web Interface, a system that allowed organizations to report on a sample of 248 Medicare beneficiaries per year. This approach was simpler from a data perspective, but CMS phased it out because it didn't capture comprehensive, all-payer performance data.
The CMS Web Interface completely sunset after 2024. Now all MSSP ACOs must report through the APP using either electronic clinical quality measures (eCQMs), MIPS CQMs, or Medicare CQMs across all their patients, all payers, for the entire 365-day performance year. The shift moves ACOs from sample-based reporting to comprehensive, all-patient reporting—a fundamental change in data collection and submission methodology.
Reporting Requirements for ACOs in 2026 and Beyond
Required Quality Measures
Starting in 2026, MSSP ACOs must report the APP Plus quality measure set, an expanded framework that requires reporting on multiple measure categories.
eCQM and CQM Reporting: ACOs must actively report on at least four electronic or traditional clinical quality measures. These measures span clinical quality categories like cardiovascular care, diabetes management, and infection prevention. Most measures require a minimum of 20 cases and must achieve 75% data completeness—meaning your organization must capture data on at least 75% of eligible patients in your denominator.
CAHPS for MIPS Survey: Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey administration is mandatory. This patient experience survey captures feedback on access to care, communication, and care coordination. ACOs conduct or field this survey during the reporting period, and results are part of your overall quality score.
Administrative Claims Measures: CMS calculates two additional outcome measures using Medicare claims data directly—readmission rates and mortality. Your ACO doesn't have to submit this data; CMS pulls it automatically from billing records.
Reporting Pathways and Deadlines
ACOs can choose from three reporting collection types: eCQMs, MIPS CQMs, or Medicare CQMs. Each has tradeoffs in terms of burden and incentives.
eCQMs (electronic clinical quality measures) require your EHR systems to generate QRDA-I files—structured clinical data formatted according to CMS standards. This approach captures comprehensive data but demands significant EHR integration and data validation work upfront. However, CMS incentivizes eCQM reporting by adding one measure achievement point for each submitted eCQM (the complex organization adjustment), which can boost your quality score by up to 10%.
MIPS CQMs (Merit-Based Incentive Payment System clinical quality measures) are traditional quality measures reported using claims and clinical data combined. These measures are easier to calculate than eCQMs but cover a narrower population.
Medicare CQMs represent a transitional option reporting MIPS CQMs for your fee-for-service Medicare population only, rather than all-payer data. CMS will remove this option in 2027, so it's intended only as a stepping stone for organizations not yet ready for eCQM reporting.
Submission Timeline: Quality data submissions to CMS occur through the QPP portal or through a CMS Qualified Registry. Most submissions occur in March or April following the performance year. Missing even one deadline can result in your ACO not meeting the quality performance standard, disqualifying you from shared savings.
Data Completeness and Case Minimums
Regulatory requirements are specific: each measure must include at least 20 cases and achieve 75% data completeness. "Data completeness" means that for every patient who should be included in the measure, your organization has actually captured and reported the necessary clinical data. If you have 100 diabetic patients in your denominator but only report data for 70 of them, you've failed to meet the 75% threshold and that measure won't count toward your quality score.
Do ACO Participants Still Have to Report MIPS?
This question creates confusion because the answer is both yes and no—it depends on a clinician's status within your ACO.
ACO Entity vs. Individual Obligations
Your ACO reports quality measures on behalf of all participating clinicians. This APP reporting satisfies the quality component of MIPS scoring for your clinicians. However, individual clinicians must still report on the Promoting Interoperability (PI) performance category—unless they achieve Qualifying Participant (QP) status under an Advanced APM.
Promoting Interoperability measures require clinicians to use certified electronic health record technology (CEHRT) and attest to specific security, interoperability, and health information exchange objectives. Unlike quality measures, which are submitted at the ACO level, PI requirements are reported at the individual NPI or tax identification number (TIN) level. Each TIN within your ACO must coordinate PI reporting, either submitting it themselves or working with a qualified vendor to submit on their behalf.
Qualifying Participant Status and MIPS Exemption
If a clinician within your ACO achieves Qualifying Participant (QP) status under an Advanced APM, they're exempt from MIPS entirely—including PI reporting. QP status requires that a clinician meet specific thresholds related to their billing under the APM. For MSSP ACOs, clinicians generally need to bill at least 35% of their Medicare Part B professional services through the ACO to achieve QP status.
Clinicians who don't meet QP thresholds remain subject to standard MIPS rules, meaning they must report Promoting Interoperability measures to avoid payment adjustments.
How to Prepare Your ACO for Success
Assess Your Data Infrastructure
Start with an honest assessment of your current systems. Where does patient data live across your ACO? If you have multiple tax identification numbers (TINs) or use different EHR vendors across your network, data aggregation becomes exponentially more complex.
Map out your data sources: primary EHRs, lab systems, billing platforms, and any specialty systems. Identify where the data you need for quality measures actually exists and whether your current systems can generate the structured data formats CMS requires (particularly QRDA-I files for eCQMs). This audit often reveals gaps—practices running on older EHR versions, standalone labs that don't integrate with your EHR, or billing systems that don't talk to clinical systems.
Establish Cross-Organizational Collaboration
Quality reporting success requires more than IT and quality teams working in isolation. You need coordination across clinical, operational, and financial functions.
Clinical leadership must understand which measures your ACO will report and ensure clinical workflows support data capture. For example, if you're reporting on diabetes management measures, your clinicians need to document key elements—HbA1c tests, blood pressure readings, statin use—in a way your EHR can extract and calculate.
IT teams must manage EHR integrations, ensure CEHRT certification is maintained, and validate that measure calculations are accurate. Beginning in 2026, 100% of your MIPS APM participants must use certified EHR technology—there are no exceptions. This is a major shift from prior years, when you could get away with partial CEHRT compliance.
Quality and compliance teams oversee measure definition, data validation, and submission timelines.
Finance teams monitor the relationship between quality, performance, and shared savings potential.
Implement Data Validation and Monitoring Tools
Real-time performance monitoring is critical. Rather than scrambling to validate data in March before submission, continuously track your performance throughout the year. Build dashboards that show:
- Performance on each quality measure by TIN and the clinician
- Data completeness rates (percentage of eligible patients with reported data)
- Trends over time (are you improving, declining, or flat?)
- Cases not meeting denominator or numerator criteria
This visibility allows you to catch data quality issues early and intervene with practices that are underperforming on specific measures. If you're trending toward failing to meet the 40th percentile threshold for shared savings eligibility, you can still take corrective action mid-year.
Consider a Qualified Registry or QCDR
Many ACOs lack the internal technical expertise to build eCQM reporting infrastructure from scratch. Partnering with a CMS Qualified Registry (a vendor certified by CMS to collect and submit quality data) or a Qualified Clinical Data Registry (QCDR) can significantly reduce burden.
Qualified Registries handle data aggregation, validation, and submission to CMS. They manage the technical complexity of QRDA-I file generation and ensure your data meets CMS specifications before submission. This outsourcing approach costs money but often costs less than building the infrastructure internally and carries lower risk of submission errors.
How Medisolv Supports ACO Quality Reporting
Centralized Performance Dashboards
Medisolv's ACO reporting platform consolidates quality data from multiple TINs, EHRs, and billing systems into unified dashboards. Instead of managing separate spreadsheets for each practice or EHR, your team sees performance across the entire ACO at a glance. You can drill down to individual clinician, measure, and patient levels, making it easy to identify underperforming areas and intervene.
Full eCQM and MIPS CQM Tracking
The platform natively supports both eCQM and MIPS CQM reporting methodologies. As CMS continues its push toward digital quality measurement, having infrastructure that handles eCQMs positions your ACO ahead of the curve. Medisolv calculates measures continuously throughout the year, so you're not dependent on quarterly data pulls or year-end scrambles.
Expert-Led Onboarding and Measure Guidance
ACO reporting is complex, and regulatory changes happen frequently. Medisolv's Advisory Services team helps your organization navigate measure definitions, data validation, and CMS requirement changes. Rather than relying solely on internal resources to interpret regulatory guidance, you have access to experts who specialize in ACO compliance.
Flexibility to Evolve
As your ACO matures or as CMS requirements change, Medisolv's platform scales. Whether you're starting with MIPS CQMs and planning a gradual transition to eCQMs, or you're ready to implement comprehensive eCQM reporting across all practices immediately, the infrastructure adapts to your timeline and capabilities.
FAQ: Common Questions About ACO Quality Reporting
What happens if an ACO doesn't meet the quality performance standard?
If your ACO fails to report required quality measures, or reports them but doesn't achieve the minimum quality performance score (currently 40th percentile), the ACO is ineligible for maximum shared savings.
Do all clinicians in an ACO have to report individually?
No. Your ACO's APP quality reporting covers all clinicians' quality performance. However, participating clinicians must still report Promoting Interoperability (PI) measures at the individual or TIN level unless they qualify for an APM exemption or achieve QP status.
What's the difference between eCQMs and MIPS CQMs?
eCQMs (electronic clinical quality measures) are calculated from structured clinical data pulled directly from your EHR. MIPS CQMs are traditional clinical quality measures that can be calculated from either claims data or clinical data, but don't require the same level of EHR integration as eCQMs.
What is the CMS Web Interface and why did it sunset?
The CMS Web Interface was an older quality reporting system where ACOs could report on a sample of 248 Medicare beneficiaries per year. This approach was simpler operationally—you didn't need comprehensive all-payer data or sophisticated EHR integration.
When is the quality data submission deadline?
Quality data submissions generally occur in the March following the performance year. CMS provides a specific submission window each year—typically, the portal opens in January and closes in March. Your ACO must submit all quality data files, CAHPS survey results, and required attestations within this window.
From Compliance to Performance
Staying compliant with CMS quality reporting requirements is the floor—but it's not the finish line. The real opportunity is using quality data to drive genuine clinical improvement. ACOs that excel at shared savings don't just report quality data; they use that data to identify clinical variation, standardize best practices, and systematically improve outcomes for their patient population.
The infrastructure, processes, and expertise required to meet 2026 reporting requirements are the same infrastructure you need to transform quality data into better patient care. Whether you build these capabilities internally or partner with an experienced vendor, starting now is essential.
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