Understanding New Quality Requirements:
The APM Performance Pathway

After a multi-year advocacy campaign, NAACOS was successful in securing Medicare Shared Savings Program (MSSP) ACOs three additional years to report quality measures through the Web Interface (WI). In the 2021 Medicare Physician Fee Schedule (MPFS) Rule, CMS finalized a major overhaul of the quality reporting and assessment structure for MSSP ACOs, including a mandatory move away from WI reporting beginning in 2022. NAACOS advocated for a more phased-in approach to allow the ACO and electronic health record (EHR) industries more time to correct deficiencies and to allow CMS to more thoughtfully approach transitioning to mandatory use of digital measures aggregated at the ACO level. As a result of NAACOS advocacy, in the 2022 MPFS Rule CMS adopted a longer timeframe to allow ACOs to transition gradually, requiring a full transition to electronic clinical quality measure (eCQM) reporting starting in 2025. 

CMS created the APM Performance Pathway (APP) to better align quality measurement approaches for MSSP with the Quality Payment Program (QPP) Merit-Based Incentive Payment System (MIPS). The APP includes notable differences in both reporting and scoring policies for MSSP ACOs, outlined in this resource. Notably, the changes include a departure from the current quality scoring approach for all MSSP ACOs as well as significant changes to how ACO quality scores contribute to ACO shared savings and loss rates, effective for all ACOs beginning with Performance Year (PY) 2021. 

This resource outlines the APP quality criteria for ACOs in 2021 through 2025 used to assess quality in the MSSP. Please note, CMS will use the same MSSP ACO quality score to apply quality scores in MIPS for those ACOs subject to that program. For more information on how ACOs are assessed in MIPS, please refer to the NAACOS ACO Guide to MACRA.