The Path to Shared Savings: A Guide to 2026 ACO Quality Performance Standards

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.

Reporting Pathways

• For eCQMs or MIPS CQMs: ACOs that report all five APP Plus measures and meet data completeness for each may meet the quality performance standard by achieving at least the 10th-percentile benchmark on one outcome measure and at least the 40th-percentile benchmark on one of the remaining APP Plus measures. 
• For Medicare CQMs: ACOs must meet the quality performance standard by achieving an overall quality score of at least 73.85. 

What’s Changed for 2026

• The quality performance standard decreased from 76.70 to 73.85, slightly lowering the overall quality-score threshold. 
• Two new measures were added, bringing the APP Plus measure set to eight total measures:
  • #113 (CMS130) Colorectal Cancer Screening; and 
  • #484 Risk-Standardized Hospital Admissions for Multiple Chronic Conditions (administrative claims-based)
• MIPS CQMs were originally scheduled to expire as a reporting option after 2026. CMS is proposing to extend their availability for the 2027 performance year and subsequent years, but this proposal has not yet been finalized. 
   

The four outcome measures applicable for the 10/40 Rule and alternative quality performance standard are: 

• 001 (Glycemic Status Assessment >9%)
• 236 (Controlling High Blood Pressure)
• 479 (30-Day All-Cause Readmission)
• 484 (Risk-Standardized Hospital Admissions for Multiple Chronic Conditions)

*Measures 479 and 484 are calculated by CMS from administrative claims — ACOs do not submit them directly.

Everything below spells out what the Quality Performance Standard means — measure by measure — for eCQMs, MIPS CQMs, and Medicare CQMs.

1 · eCQMs (all-payer)

1.1 · 40th Percentile Threshold

To achieve an overall quality score of at least 73.85, an ACO would need to average approximately 7.385 points across the measures included in its quality score.

Note: Measures 112 and 113 do not have eCQM benchmarks available for 2026. CMS may establish performance-period benchmarks after the submission period if sufficient data are available. Measures 479 and 484 are administrative claims-based measures calculated by CMS, while CAHPS is administered by a CMS-approved survey vendor and scored by CMS.

1.2 · 10/40 Rule: 1 outcome ≥ 10th percentile, 1 other ≥ 40th percentile

To qualify for the eCQM/MIPS CQM reporting incentive, ACOs must report all five APP Plus measures, meet data completeness for each, and meet the applicable performance benchmarks on at least two measures: one qualifying outcome measure at or above the 10th percentile and at least one of the remaining APP Plus measures at or above the 40th percentile.

One potential combination using the 2026 eCQM benchmarks is Measure 001 as the outcome measure and Measure 236 as the additional measure:

TIP: ACOs that achieve ≤ 93.98% on A1c poor control (10th percentile) and ≥ 65.61% on BP control (40th percentile), and ensure data completeness across all five eCQMs, meet the 10/40 Rule and qualify for the maximum shared savings rate.

2 · MIPS CQMs (all-payer)

⚠ Important: CMS has proposed extending MIPS CQMs as an APP Plus reporting option for the 2027 performance year and subsequent years. If finalized, the proposal would allow ACOs to continue using this reporting option beyond 2026.

2.1 · 40th Percentile Threshold

The same calculation applies to MIPS CQMs: an ACO would need to average approximately 7.385 points across the measures included in its quality score.

Measures 112 and 113 do not have MIPS CQM benchmarks available for 2026. CMS may establish performance-period benchmarks after the submission period if sufficient data are available. 

*Measure 134 is capped at 7 points; earning 7.385 points on this measure is not attainable. 

Measures 001 and 236 may provide a more practical path for meeting the 10/40 Rule:

 TIP: ACOs that achieve ≤ 90% on A1c poor control (10th percentile) and ≥ 40% on BP control (40th percentile), while meeting data completeness on all five MIPS CQMs, qualify for the maximum shared savings rate.

3 · Medicare CQMs

40th Percentile Threshold (Only Path for Medicare CQMs)

To meet the required overall quality performance level in 2026, ACOs must achieve a composite quality score of at least 73.85. ACOs reporting one or more measures as Medicare CQMs are not eligible for the eCQM/MIPS CQM reporting incentive.

CMS has established flat benchmarks for Measures 112 and 113 for 2026 and is proposing to apply flat benchmarks to Measures 001, 134, and 236. If finalized, all five APP Plus Medicare CQMs would be scored using flat benchmarks, with estimated performance targets outlined in the table below.

*The CAHPS measure and the two administrative claims-based measures are also included in the overall quality score. An ACO’s scores may vary by measure, but the average across all scored measures must be sufficient to achieve an overall quality score of at least 73.85.

Operational Checklist

1. Conduct a midyear mock submission — Verify projected decile scores in the EHR or registry against the applicable benchmarks above.
2. Evaluate the 10/40 Rule when reporting eCQMs or MIPS CQMs — Measures 001 and 236 may provide a practical pathway. Meeting both benchmarks can satisfy the quality performance standard, provided all reporting and data-completeness requirements are met.
3. Focus resources - If the quality performance score of ≥ 73.85 for Medicare CQMs seems out of reach, consider switching to MIPS CQMs or eCQMs reporting as soon as possible. MDinteractive can help you evaluate and report across all these options. Schedule an MDinteractive ACO Reporting Demo to get started.
4. Watch inverse logic — Lower performance rates are better for Measure 001. Confirm that dashboards interpret inverse benchmarks correctly. 
5. Account for CMS-calculated measures — Measures 479 and 484 are calculated from administrative claims and are not submitted by the ACO. The CAHPS for MIPS survey is administered by a CMS-approved vendor and scored by CMS. All three measures contribute to the ACO’s overall quality score.
6. Document reporting logic — Document numerator and denominator calculations, exclusions, and any identified data issues.

Key Takeaways

• The 2026 quality performance standard is 73.85, down from 76.70 in 2025.
• Under eCQMs, achieving ≤93.98% on Measure 001 and ≥65.61% on Measure 236 can satisfy the 10/40 Rule and make the ACO eligible for the maximum sharing rate, provided all reporting requirements are met. 
• Under MIPS CQMs, achieving ≤90% on Measure 001 and ≥40% on Measure 236 can satisfy the 10/40 Rule. CMS has proposed extending this reporting option and its associated reporting incentive beyond 2026.
• For Medicare CQMs, ACOs may meet the quality performance standard by achieving an overall quality score of ≥73.85. CMS has proposed applying flat benchmarks to all five Medicare CQMs for 2026.
• Measures 112 and 113 do not have eCQM or MIPS CQM benchmarks available for 2026.
• Measures 479 and 484 are calculated by CMS, while CAHPS is administered by a CMS-approved survey vendor and scored by CMS. These three measures contribute to the ACO’s overall quality score.

Explore your 2026 reporting options — schedule your ACO reporting demo with MDinteractive.