Thinking of Terminating Your ACO? Know the 30-Day Notice Rule First

ACO Voluntary Termination: 30-Day Advance Notice Required

If your Accountable Care Organization (ACO) is considering ending its participation in the Medicare Shared Savings Program, it is important to understand the timing rules and financial consequences before you act. CMS requires at least 30 calendar days' advance written notice for any voluntary termination — and the effective date you choose has real implications for shared savings, shared losses, and quality reporting.

30-Day Advance Notice Requirement

Your ACO must provide at least 30 calendar days' advance written notice to CMS and to your ACO participants of your decision to terminate the ACO's Participation Agreement, including the effective date of termination.

For example:

An ACO choosing an effective termination date of June 30 must submit a termination request to CMS and notify its ACO participants by June 1.
An ACO choosing an effective termination date of December 30 must submit a termination request to CMS and notify its ACO participants by December 1.

To voluntarily terminate, the ACO Executive or Authorized to Sign Contacts (primary or secondary) must submit a voluntary termination request in ACO-MS. Step-by-step instructions are available in the Submitting a Voluntary Termination Notice in ACO-MS tip sheet in the ACO-MS Knowledge Library.

Financial Impacts of Voluntary Termination

The effective date of termination determines whether your ACO is financially reconciled and whether it is eligible for shared savings or liable for shared losses. The table below summarizes the financial impact across one-sided and two-sided tracks.

Effective Date of Termination	One-Sided Tracks: BASIC Track Levels A and B			Two-Sided Tracks: BASIC Levels C, D, and E & ENHANCED Track
Effective Date of Termination	Financially Reconciled	Eligible for Shared Savings	Liable for Shared Losses	Financially Reconciled	Eligible for Shared Savings	Liable for Shared Losses
January 1 – June 30	No	No	N/A	No	No	No
July 1 – December 30	No	No	N/A	Yes	No	Yes (prorated)
December 31	Yes	Yes	N/A	Yes	Yes	Yes

Quality Reporting Options by Termination Date

The effective date of termination also affects whether your ACO can — or must — report the APM Performance Pathway (APP) Plus quality measure set at the APM entity level, and whether MIPS-eligible clinicians in the ACO participant TINs must report separately through MIPS.

Effective Date of Termination	One-Sided Tracks (BASIC A, B) and Two-Sided Tracks (BASIC C, D, E and ENHANCED)
January 1 – March 30	Cannot report the APP Plus quality measure set at the APM entity level. MIPS-eligible clinicians in the ACO participant TINs must report quality data to MIPS under one of the available group or individual reporting options.
March 31 – June 30	Optional to report the APP Plus quality measure set at the APM entity level. If the ACO does not report APP Plus at the APM Entity level, MIPS-eligible clinicians in the ACO participant TINs must report quality data to MIPS under one of the available group or individual reporting options.
July 1 – December 30	One-sided Track: Optional to report APP Plus at the APM entity level. Two-sided Track: Must report APP Plus at the APM entity level to avoid owing maximum shared losses. ACOs that do not report via this option are liable for the maximum amount of shared losses under the applicable two-sided model. If the ACO does not report APP Plus at the APM Entity level, MIPS-eligible clinicians in the ACO participant TINs must report quality data to MIPS under one of the available group or individual reporting options.
December 31	One-sided Track: Must report APP Plus at the APM entity level to receive shared savings. Two-sided Track: Must report APP Plus at the APM entity level to receive shared savings and avoid owing maximum losses. ACOs that do not report via this option are liable for the maximum amount of shared losses under the applicable two-sided model. If the ACO does not report APP Plus at the APM Entity level, MIPS-eligible clinicians in the ACO participant TINs must report quality data to MIPS under one of the available group or individual reporting options.

Key Takeaways

Plan the notice date carefully. Submit the termination request in ACO-MS and notify your ACO participants at least 30 calendar days before the effective date.
Mid-year termination has financial consequences. Two-sided ACOs that terminate between July 1 and December 30 are still financially reconciled and may owe prorated shared losses.
A year-end (December 31) termination preserves shared savings eligibility for ACOs that complete quality reporting through APP Plus at the APM entity level.
Quality reporting obligations don't disappear with termination. Depending on the effective date, your clinicians may still need to report to MIPS individually or as a group.

Where to Learn More

For full details on voluntary termination requirements (42 CFR § 425.221), close-out procedures, and payment impacts of early termination, refer to the Medicare Shared Savings Program Voluntary Terminations document and the Submitting a Voluntary Termination Notice in ACO-MS tip sheet — both available in the Knowledge Library tab of ACO-MS.

Source: CMS Medicare Shared Savings Program, ACO Spotlight Newsletter — Issue 5, May 21, 2026.

If you have questions about how a voluntary termination would affect your ACO's MIPS quality reporting or APP Plus submission, contact our MIPS experts for guidance.

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