APP Plus in 2027: Your Reporting Pathway Is Now a Strategic Decision
The APP Plus measure set may be the same. The population, aggregation burden, scoring opportunity, and technology requirements behind your submission may not be.
For MSSP ACO quality leaders, that distinction matters.
CMS is proposing several changes for performance year 2027 that would give ACOs more flexibility in how they report APP Plus quality measures. That sounds like good news, and in many ways it is.
But more choices do not automatically make reporting simpler.
Under the CY 2027 Physician Fee Schedule proposed rule, ACOs could potentially choose among eCQMs, MIPS CQMs, Medicare CQMs, and a new Medicare eCQM collection type, including combinations of those approaches for the five ACO-reported APP Plus measures. CMS is also proposing new TIN-level exclusions, broader use of flat benchmarks, continued reporting incentives for certain pathways, and changes intended to reduce data-aggregation barriers. (Centers for Medicare & Medicaid Services)
At Chirpy Bird, we think that makes one question especially important:
Which APP Plus reporting pathway can your ACO execute accurately, completely, and defensibly with the technology and data relationships you actually have?
That is the question I would answer before 2027 reporting strategy gets locked into a vendor contract.
1. Start With the Proposed 2027 APP Plus Measure Set
APP Plus is already required for Medicare Shared Savings Program ACOs. CMS replaced the former APP measure set with APP Plus beginning in performance year 2025. (Centers for Medicare & Medicaid Services)
For 2027, CMS proposes an eight-measure APP Plus set:
Five measures reported by the ACO
Two administrative claims measures
One CAHPS for MIPS survey measure
CMS, per CMS.gov, proposes removing Initiation and Engagement of Substance Use Disorder Treatment (Quality ID 305) and Adult Immunization Status (Quality ID 493). The five ACO-reported clinical measures would be diabetes glycemic status, depression screening and follow-up, controlling high blood pressure, breast cancer screening, and colorectal cancer screening. That measure list is only half the story.
The operational difference is which patient population your ACO must assemble for those measures and how your systems produce the data.
That is where reporting-pathway strategy begins.
2. Compare the Reporting Population Before You Compare Vendors
The collection types are not interchangeable simply because they can report the same clinical measure.
eCQMs
Traditional electronic clinical quality measures, or eCQMs, generally require the ACO to aggregate the applicable all-patient, all-payer population across participating organizations.
For an ACO with multiple TINs, several EHR platforms, acquired practices, specialty systems, and inconsistent interfaces, this can become a significant data-management exercise.
The advantage is that CMS continues to view electronic quality measurement as a core direction for digital quality reporting. eCQM reporting may also carry scoring advantages that we will discuss shortly. (CMS.gov)
MIPS CQMs
MIPS CQMs provide another reporting pathway and have historically offered ACOs more flexibility in assembling quality data.
Under current policy, MIPS CQMs were scheduled to stop being available to MSSP ACOs after 2026.
CMS is now proposing to extend MIPS CQM availability for performance year 2027 and subsequent years, specifically acknowledging that requiring ACOs to change collection types could create unnecessary administrative burden while organizations continue moving toward digital quality measurement. (CMS.gov)
That is a meaningful proposal for ACOs whose current vendors and data pipelines are already built around MIPS CQM reporting.
Medicare CQMs
Medicare CQMs narrow the population compared with all-payer reporting and were designed partly to reduce the data-aggregation and patient-matching burden ACOs experience.
CMS already revised the definition of beneficiaries eligible for Medicare CQMs in the CY 2026 final rule to create greater overlap with beneficiaries assignable to the ACO.
For 2027, CMS proposes going further by aligning that population more closely with the ACO’s assigned beneficiary list.
Proposed Medicare eCQMs
This is one of the more interesting 2027 proposals.
CMS proposes creating Medicare eCQMs as a new APP Plus collection type.
Think of a Medicare eCQM as largely following the eCQM measure specification, but instead of reporting across the all-patient, all-payer population, the ACO would report on its assigned Medicare beneficiaries.
CMS explicitly connects this proposal to a problem many ACO quality leaders already know well: an organization may want to move toward electronic quality measurement but lack the infrastructure to aggregate all-payer data across the entire ACO. (CMS.gov)
That could make Medicare eCQMs an attractive bridge.
But there is a tradeoff.
3. Flat Benchmarks Change the Scoring Conversation
Reporting population is only one variable.
Benchmark methodology matters too.
CMS proposes that, beginning in 2027, all Medicare CQM measures would use flat benchmarks.
CMS also proposes flat benchmarks for the new Medicare eCQM collection type.
Flat benchmarks can provide more predictability than historical benchmarks because an ACO can understand the performance thresholds without waiting for a future benchmark calculation based on peer performance.
CMS has previously described flat benchmarks as a way for strong Medicare CQM performers to earn high achievement points while maintaining room for improvement. But I would not choose a reporting pathway based on the phrase “flat benchmark” alone.
An ACO should model:
Our actual performance rate → applicable benchmark → expected points → quality-performance-standard implications
Then compare that result with the operational cost and data risk of each pathway.
A simpler denominator is not automatically the better financial choice.
4. Do Not Overlook the Reporting Incentive
CMS is also proposing to continue an important incentive associated with electronic and MIPS CQM reporting.
Under existing APP Plus policy, eligible ACOs reporting the required eCQMs or MIPS CQMs can qualify for a reporting incentive that can help the ACO satisfy the Shared Savings Program quality performance standard and remain eligible for the maximum shared-savings rate available under its track.
For 2027, CMS proposes extending both MIPS CQM availability and the associated reporting incentive. (CMS.gov)
By contrast, CMS specifically states that an ACO choosing the proposed Medicare eCQM pathway would not qualify for the eCQM/MIPS CQM reporting incentive or the Complex Organization Adjustment.
That creates a real strategic tradeoff:
Less aggregation burden may come with fewer scoring advantages.
That's why APP Plus pathway selection should involve your quality, finance, data, and operational teams, not just the reporting vendor.
5. The Proposed TIN Exclusion Policy Could Help, But 95% Still Matters
Another major proposal addresses one of the hardest realities of ACO-level quality reporting:
Sometimes one participant TIN creates an outsized data problem.
A practice may close unexpectedly.
A specialty group may use CEHRT that does not support the APP Plus measures.
Or another circumstance outside the ACO’s control may prevent usable reporting.
CMS proposes allowing ACOs, beginning with performance year 2026, to exclude certain participant TINs from applicable APP Plus submissions when specified conditions are met. That does not create an unlimited exclusion policy.
The proposed safeguard is significant:
After the exclusions, the remaining participant TINs must represent at least 95% of the beneficiaries assigned to the ACO before the measure specifications are applied.
And the existing MIPS data completeness requirement still applies to each submitted measure. CMS states that the ACO must report at least 75% of the applicable beneficiaries meeting that measure’s denominator criteria. Those are two different tests.
An ACO could therefore have a valid reason to exclude a participant TIN and still discover that the exclusion jeopardizes the 95% assigned-beneficiary threshold.
That means quality teams should not wait until submission season to perform this calculation.
Build a participant-level coverage model now.
For every TIN, know:
Assigned beneficiaries → EHR → collection capability → measure support → aggregation status → exclusion exposure
Then ask what happens to your coverage percentage if that TIN drops out.
6. Data Aggregation May Decide Which Path Is Realistic
This is where policy becomes operations.
Consider an ACO with 40 participating TINs using seven EHR products.
One reporting pathway may look ideal on paper.
But can the organization actually:
identify the correct patient population?
collect data from every required participant?
normalize data across systems?
resolve duplicate patients?
maintain measure-level provenance?
validate numerator and denominator logic?
reconcile the submitted population against assignment?
reproduce the submission if CMS questions it?
That is APP Plus reporting readiness.
CMS’s Medicare eCQM proposal is itself an acknowledgment that all-payer aggregation remains difficult for some ACOs. Do not hide that operational reality behind a vendor promise that says, “Yes, we support APP Plus.”
Support how?
That is the next question.
7. Your Vendor Capability Review Needs to Get More Specific
I would ask every APP Plus vendor to demonstrate its capability against the pathway the ACO is actually considering.
For 2027 planning, ask:
Population capability: Can you support eCQM, MIPS CQM, Medicare CQM, and proposed Medicare eCQM populations?
Multi-TIN aggregation: How do you combine data from different practices and EHRs?
Assignment reconciliation: Can you reconcile CMS assigned-beneficiary information against the reporting population?
TIN-level visibility: Can we see coverage and data completeness by participant TIN?
Exclusion modeling: Can you show what happens to our 95% assigned-beneficiary coverage if a TIN qualifies for exclusion?
Measure validation: Can we inspect numerator, denominator, exclusion, and exception logic before submission?
Benchmark modeling: Can you show expected scoring under the applicable benchmark methodology?
Audit evidence: Can you preserve source data, validation results, submission files, and version history?
2027 roadmap: If CMS finalizes Medicare eCQMs, when will your platform support them?
That final question matters.
A sales presentation that says “APP Plus ready” is not enough for 2027.
The vendor needs to be reporting-pathway ready.
8. Do Not Pick the Pathway in Isolation
At Chirpy Bird, we would evaluate the 2027 reporting decision across four dimensions.
Population: Which patients must you report?
Performance: How do your actual rates interact with the applicable benchmark and incentives?
Infrastructure: Can your EHRs and aggregation process produce complete, valid data?
Defensibility: Can you prove how you built the submission?
An ACO with mature interoperability and strong all-payer aggregation may reach one conclusion.
A clinically diverse ACO with many specialty TINs and fragmented EHR infrastructure may reach another.
Neither answer is automatically wrong.
What becomes risky is allowing the reporting pathway to emerge accidentally because it happens to be the only option your current vendor supports.
APP Plus Flexibility Is Valuable Only If You Use It Strategically
CMS appears to be acknowledging something ACO quality teams have been saying for years: the technical burden of assembling quality data can be as consequential as the measure itself.
The proposed 2027 policies could give MSSP ACOs more flexibility through continued MIPS CQM reporting, broader use of flat benchmarks, Medicare eCQMs, targeted TIN exclusions, and other changes intended to address aggregation barriers. (CMS.gov)
But flexibility creates a new responsibility.
You need to know why you chose your pathway.
Before finalizing 2027 contracts, I would compare your reporting population, benchmark methodology, incentive eligibility, participant-TIN coverage, data-aggregation burden, and vendor capabilities side by side.
Do not ask only, “Can we report APP Plus?”
Ask:
“Which APP Plus pathway gives this ACO the strongest combination of performance opportunity, operational feasibility, and defensible data?”
That is a much more useful question.
Ready to review your 2027 reporting pathway?
Book an APP Plus reporting-pathway review with Chirpy Bird.
We can help your ACO compare collection types, test participant coverage, identify data-aggregation risk, evaluate vendor capabilities, and build a reporting strategy before the proposed changes become final requirements.
