In 2025, Medicare Shared Savings Program Accountable Care Organizations (ACOs) were required to report the APP Plus measure set for the first time. For 2026, the measure set expands to eight measures, and CMS has set the quality performance standard at 73.85, based on the 40th percentile of MIPS Quality performance category scores. This is down from 76.70 in 2025. An ACO’s reporting pathway affects how it may meet this standard and become eligible for the maximum sharing rate available under its track. Actual shared savings remain dependent on the ACO’s financial performance.

CMS released the 2027 Medicare Physician Fee Schedule (PFS) proposed rule on July 14, 2026. The rule proposes to sunset traditional MIPS after the 2028 performance period, giving clinicians a firm timeline for the long-anticipated transition to MIPS Value Pathways (MVPs). It also includes changes to quality reporting, the Promoting Interoperability performance category, and Advanced APM participation. The public comment period closes September 14, 2026, and CMS is expected to publish a final rule later this year. Understanding what’s being proposed and how it may affect future reporting requirements is critical, particularly as the program moves toward full MVP implementation.

On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the 2027 Medicare Physician Fee Schedule (PFS) proposed rule, which includes some of the most significant proposed changes to the Medicare Shared Savings Program (MSSP) in recent years. While the rule touches on benchmarking, beneficiary assignment, and engagement, the quality reporting and CEHRT provisions deserve particular attention. The public comment period closes September 14, 2026. Because these policies are proposed, they are not yet final. CMS will review public comments before issuing the final rule later this year.

Beginning January 1, 2027, the Centers for Medicare & Medicaid Services (CMS) will launch the Ambulatory Specialty Model (ASM), a mandatory payment model designed to expand value-based care into outpatient specialty practice. Unlike previous CMS Innovation Center models that largely focused on hospitals or primary care, ASM is aimed specifically at specialists managing high-cost chronic conditions in ambulatory settings.

With the 2026 performance year well underway, MSSP ACOs should be using ongoing quality measure submissions and performance review to evaluate how reporting workflows, data completeness, and measure performance are trending across participating organizations. More than a reporting exercise, ongoing performance monitoring helps organizations identify workflow gaps, validate data capture, and stay on track throughout the performance year. As organizations review mid-year performance, each APP measure presents its own operational, documentation, and reporting considerations heading into the second half of 2026.

For many ACOs, the shift to eCQM reporting creates a real operational challenge because participating practices often use different EHR systems, some of which may not be certified for all required APM Performance Pathway (APP) eCQM measures. With more than 25 years of CMS quality reporting experience, MDinteractive helps ACOs navigate this shift by transforming clinical and administrative data from disparate EHR systems — accessed via direct export or FHIR APIs — into compliant APP eCQM submissions, even when participating EHRs may not support all measures natively.

2026 MIPS reporting requires practices to stay proactive, organized, and prepared throughout the performance year. With updates to quality measures, MIPS Value Pathways (MVPs), and measure benchmarks that can significantly affect scoring, early planning can help reduce reporting burdens, improve scores, and help avoid negative payment adjustments. In this article, we’ve outlined a step-by-step checklist to help your practice stay organized, reduce reporting burdens, and achieve success with 2026 MIPS.

Success in the 2026 MIPS performance year starts with staying ahead of important deadlines. From data collection to final submission, knowing what’s due and when can make all the difference in your performance outcomes. Use the timeline below to keep your team aligned, prepared, and on track all year long.