On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) released the final rule for the 2025 Medicare Physician Fee Schedule (PFS). The final rule includes several key changes affecting Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs), as CMS continues its shift towards digital quality measures (dQMs). With the CMS Web Interface ending after the 2024 performance year, the final rule focuses on the future of quality reporting by aligning with the Universal Foundation of quality measures and extending eCQM / MIPS CQM reporting incentives. This blog summarizes the changes and their implications for ACOs in 2025 and beyond.
2024 Quality Reporting Framework
CMS implemented a multi-year transition from 2021 to 2024 for MSSP ACOs to move from reporting quality data through the CMS Web Interface to using eCQMs under the Alternative Payment Model (APM) Performance Pathway (APP). MSSP ACOs are required to report quality data via the APP to meet the quality performance standard used to determine shared savings and shared losses.
In 2024, these ACOs have the option to fulfill APP quality reporting requirements by either reporting the Web Interface quality measure set (10 measures) or the APP quality measure set (3 measures via eCQMs, MIPS CQMs, and/or Medicare CQMs collection types). The 2024 performance period marks the final year that MSSP ACOs can report via the CMS Group Practice Reporting Option (GPRO) Web Interface.
For 2024, the APP quality measure set includes three measures:
- CMS 122: Diabetes: Hemoglobin A1c (HbA1c) Poor Control (Quality ID 001)
- CMS 2: Preventive Care and Screening: Screening for Depression and Follow-Up Plan (Quality ID 134)
- CMS 165: Controlling High Blood Pressure (Quality ID 236)
In addition to reporting the measures outlined above, ACOs must also administer the Consumer Assessment of Healthcare Providers Survey (CAHPS), and CMS will also calculate two measures using administrative claims data.
2025 Changes to the APP Reporting Requirements
Building on this transition, CMS intends to continue evolving its approach with the final rule, which further advances Medicare’s overall value-based care strategy for measuring and encouraging improvements in care through the MSSP and the Quality Payment Program.
The APP Plus Quality Measure Set
The APP Plus quality measure set will align with the Adult Universal Foundation measures. This new set will be mandatory for MSSP ACOs. Under the new approach, the APP Plus quality measure set will gradually expand to include eleven measures. This set will start with the measures from the current APP quality measure set and add five new measures from the Adult Universal Foundation measure set over the performance years 2025 to 2028. In 2025, the APP Plus quality measure set for MSSP ACOs will include six measures (four eCQMs/Medicare CQMs, one administrative claims measure, and the CAHPS for MIPS survey).
APP Plus Quality Measure Set for 2025
| Quality # | Measure Title | Collection Type | Measure Type |
|---|---|---|---|
| 321 | CAHPS for MIPS | CAHPS for MIPS Survey | Patient Engagement/Experience |
| 479 | Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Eligible Clinician Groups | Administrative Claims | Outcome |
| 001 | Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%) | eCQM/MIPS CQM/Medicare CQM | Intermediate Outcome |
| 134 | Preventive Care and Screening: Screening for Depression and Follow-up Plan | eCQM/MIPS CQM/Medicare CQM | Process |
| 236 | Controlling High Blood Pressure | eCQM/MIPS CQM/Medicare CQM | Intermediate Outcome |
| 112 | Breast Cancer Screening | eCQM/MIPS CQM/Medicare CQM | Process |
Timeline for Adding Adult Universal Foundation Measures to the APP Plus Set
CMS has the following timeline for adding the five Adult Universal Foundation quality measures to the APP Plus quality measure set:
| Measure Name/ID | Proposed Performance Period |
|---|---|
| Breast Cancer Screening (Quality ID 112) | 2025 |
| Colorectal Cancer Screening (Quality ID 113) | 2026 |
| Initiation and Engagement of Substance Use Disorder Treatment (Quality ID 305) | 2026 |
| Screening for Social Drivers of Health (Quality ID 487) | 2028 or the performance period that is one year after the eCQM specification becomes available, whichever is later |
| Adult Immunization Status (Quality ID 493) | 2028 or the performance period that is one year after the eCQM specification becomes available, whichever is later |
eCQMs, MIPS CQMs, and Medicare CQMs - Only Reporting Options for MSSP ACOs
Starting in performance year 2025, ACOs using the APP Plus quality measure set will have only three reporting options: eCQMs, MIPS CQMs, and Medicare CQMs. CMS will remove the MIPS CQM collection option in 2027.
Medicare CQMs are MIPS CQMs reported for an ACO’s eligible Medicare fee-for-service population instead of the ACO’s all-payer/all-patient population. Medicare CQMs will act as a transitional step toward prioritizing the adoption of eCQMs as CMS aims to fully transition to digital quality measurement in CMS quality reporting and value-based purchasing programs.
Flat Benchmarks for Medicare CQMs
Beginning in 2025, ACOs reporting Medicare CQMs would be scored using flat benchmarks for the measures’ first two performance periods in MIPS. A quality performance benchmark is the performance rate an ACO must achieve to earn the corresponding quality points for each measure. Flat benchmarks assign a performance rate range to each decile. In flat benchmarks for non-inverse measures, any performance rate at or above 90 percent would be in the top decile; any performance rate between 80 percent and 89.99 percent would be in the second highest decile, and so on. For inverse measures, this would be reversed—any performance rate at or below 10 percent would be in the top decile; any performance rate between 10.01 percent and 20 percent would be in the second highest decile, and so on.
The table below lists the flat benchmarks for a non-inverse Medicare CQM in its first two performance periods in MIPS in performance year 2025 and subsequent years:
| Decile | Performance Rate Range |
|---|---|
| 1 | < 10.00 |
| 2 | 10.00 – 19.99 |
| 3 | 20.00 – 29.99 |
| 4 | 30.00 – 39.99 |
| 5 | 40.00 – 49.99 |
| 6 | 50.00 – 59.99 |
| 7 | 60.00 – 69.99 |
| 8 | 70.00 – 79.99 |
| 9 | 80.00 – 89.99 |
| 10 | >= 90.00 |
For example, if an ACO reports a non-inverse Medicare CQM in its first two performance periods in MIPS in performance year 2025 and earns a performance rate of 55.25 percent, then the ACO would score in the 6th decile on that measure.
eCQM/MIPS CQM Reporting Incentives
To encourage ACOs to transition more quickly to eCQMs and take advantage of digital data and interoperability, CMS is extending the eCQM/MIPS CQM reporting incentive. For performance year 2025 and subsequent performance years, an ACO will meet the quality performance standard used to determine eligibility for maximum shared savings and to avoid maximum shared losses, if applicable:
If the ACO reports all of the eCQMs/MIPS CQMs in the APP Plus quality measure set applicable for a performance year, meeting the MIPS data completeness requirement for all eCQMs/MIPS CQMs;
Achieves a quality performance score equivalent to or higher than the 10th percentile of the performance benchmark on at least one of the outcome measures in the APP Plus quality measure set;
And achieves a quality performance score equivalent to or higher than the 40th percentile of the performance benchmark on at least one of the remaining measures in the APP Plus quality measure set.
However, the reporting incentive will not apply to Shared Savings Program ACOs that use the Medicare CQM collection type to report quality measures. The incentive is for all payer/all patient eCQM/MIPS CQM reporting.
Complex Organization Adjustment
CMS is adding an adjustment to address the challenges ACOs face when reporting eCQMs:
- Give one extra measure achievement point for each submitted eCQM submitted that meets data completeness and case minimum requirements.
- This adjustment would not exceed 10% of the total measure achievement points available in the quality performance category.
Merit-Based Incentive Payment System (MIPS)
CMS proposes minimal changes to MIPS for ACOs in 2025, with performance category weights remaining unchanged for those subject to MIPS. Additionally, CMS intends to maintain a 75-point performance threshold for the 2025 performance year, affecting payments in 2027.
ACOs MSSP ACOs eCQM reporting Medicare CQMs APM Performance Pathway
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