PROPOSED 2026 ACO UPDATES Shared Savings Program Participants

The 2026 CMS proposed rule brings several significant updates for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). Here’s a breakdown for ACO leaders and participants:

1. Required Use of APP: ACOs Must Report Through the APM Performance Pathway

• All MSSP ACOs in MIPS must submit quality data through the Alternative Payment Model Performance Pathway (APP).

• Changes to the APP measure set continue, with some measures slated for removal, others substituted, and new digital or electronic clinical quality measures introduced.

2. Emphasis on Digital and Population Health

• CMS is accelerating the shift to digital quality measurement, expecting ACOs to harness electronic data for more actionable, real-time feedback and improved patient care.

• The end goal is more robust benchmarking and the ability to better demonstrate value and quality improvement.

3. Revised Quality Standards and Performance Thresholds

• Eligibility thresholds for sharing savings are proposed to increase, requiring ACOs to meet higher quality benchmarks.

• These adjustments are intended to align ACO performance with national trends and incentivize being above average on critical care quality domains.

4. Data Submission Flexibility

• New flexibilities and streamlined reporting options are highlighted, particularly for smaller or rural ACOs to reduce administrative burden.

• A phased transition to digital measures allows ACOs more time to adapt to the new requirements.

5. Benchmarking and Attribution Updates

• Proposals include revisions to how beneficiaries are attributed to ACOs.

• Benchmark methodologies are being recalibrated, with more contemporary data sources and updated risk adjustments ensuring a level playing field.

6. Promoting Interoperability Extended to ACOs

• ACOs must comply with Promoting Interoperability rules that mirror those for group practices, reinforcing CMS's push for seamless, patient-centered information exchange.

Check out the fact sheet and be on the lookout for an upcoming webinar!

ACOs should prepare for a more digital, outcomes-oriented future. Reviewing their APP reporting readiness, understanding the implications of evolving quality benchmarks, and getting involved in public commentary are critical steps. CMS is inviting feedback on how quickly digital measurement should advance and on efforts to ease reporting while driving real performance improvement.

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We offer expert support in ALL categories on a pay-as-you go basis. You use your EMR and or registry and we help with ALL of the rest to help with Quality, Promoting Interoperability, Improvement Activities, Cost and Submission of all data. 

If you’re ready for a dedicated MIPS expert as part of your team contact us today!

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