ACO Quality Reporting and CEHRT Requirements for 2027

Medicare Shared Savings Program (MSSP) ACOs must report the APP Plus quality measure set for performance year (PY) 2027 — eight measures covering clinical outcomes, hospital admissions, and patient experience. 

CMS removed two measures originally planned for future addition, extended the MIPS CQM collection type, and created a new Medicare eCQM reporting option. 

Starting in PY 2027, ACOs also meet the CEHRT use requirement through one of three activity paths instead of the prior approach tied to MIPS Promoting Interoperability reporting.

The CY 2027 PFS final rule (CMS-1848-F), effective January 1, 2027, finalizes all of it. Here is what this article covers:

• How the three CEHRT activity paths work
• Data completeness thresholds and TIN-level exclusions
• Collection type options (including the new Medicare eCQM)
• The eight APP Plus measures and why two planned additions were dropped
• What separates the ACO-level CEHRT requirement from clinician-level MIPS PI

What are the eight APP Plus measures for PY 2027?

The APP Plus measure set for PY 2027 includes five ACO-reported clinical measures, two administrative claims-based measures, and the CAHPS for MIPS Survey measure. ACOs must report the full set annually.

Quality ID	Measure	Collection type
321	CAHPS for MIPS	CAHPS survey
479	Hospital-Wide 30-Day All-Cause Unplanned Readmission Rate	Administrative claims
484	Risk-Standardized Hospital Admission Rates for Multiple Chronic Conditions	Administrative claims
001	Diabetes — Glycemic Status Assessment Greater Than 9%	eCQM, MIPS CQM, Medicare CQM, or Medicare eCQM
134	Screening for Depression and Follow-Up Plan	eCQM, MIPS CQM, Medicare CQM, or Medicare eCQM
236	Controlling High Blood Pressure	eCQM, MIPS CQM, Medicare CQM, or Medicare eCQM
112	Breast Cancer Screening	eCQM, MIPS CQM, Medicare CQM, or Medicare eCQM
113	Colorectal Cancer Screening	eCQM, MIPS CQM, Medicare CQM, or Medicare eCQM

Measures removed from the planned phase-in

CMS had scheduled Quality ID 305 (Initiation and Engagement of Substance Use Disorder Treatment) for PY 2027 and Quality ID 493 (Adult Immunization Status) for a later performance year. 

The 2027 final rule removes both from the APP Plus set entirely. The eight-measure list above is the complete set — not a partial rollout.

For ACOs that had already started building data-collection workflows around these two measures, the removal simplifies the reporting year. But it also signals that CMS is narrowing the set rather than expanding it — which may change again in future rulemaking.

Why this is not the same as the Quality ID 487 removal

CMS previously removed Quality ID 487 (Screening for Social Drivers of Health) for PY 2025 and later. That was a separate decision. Do not conflate the three removals as one policy change — they happened in different rule cycles for different reasons.

What collection types can ACOs use in 2027?

For the five ACO-reported clinical measures (Quality IDs 001, 134, 236, 112, and 113), ACOs can choose from a combination of four collection types. CMS also introduced the Medicare eCQM as a new option beginning PY 2027.

eCQM versus Medicare eCQM

The most important distinction here is the reported population:

• An eCQM reports on the ACO’s all-payer, all-patient population
• A Medicare eCQM reports only on the ACO’s assigned beneficiaries

CMS created the Medicare eCQM specifically for ACOs that cannot operationally aggregate all-payer/all-patient data. 

An ACO does not issue separate measure specifications for Medicare eCQMs — it uses the existing eCQM specifications and a CMS-provided identifier to distinguish the submission.

MIPS CQM extension

CMS had originally scheduled MIPS CQM availability for MSSP ACOs to end after PY 2026. The final rule extends the collection type for PY 2027 and subsequent years and extends the related reporting incentive. 

For ACOs still running MIPS CQM workflows, this buys more time before a mandatory switch to digital measurement.

Benchmark changes

Two benchmark changes apply for PY 2027:

• All Medicare CQM measures use flat benchmarks (not standard historical benchmarks)
• Medicare eCQMs also use flat benchmarks beginning with the CY 2027 performance period

Flat benchmarking for Quality IDs 001, 134, and 236 when reported as Medicare CQMs was separately finalized for PY 2026 and later.

How do the three CEHRT activity paths work?

Starting in PY 2027, an MSSP ACO meets its CEHRT use requirement by completing one of three activities — and publicly reporting which activity it chose.

Path	What the ACO must do
eCQM/Medicare eCQM reporting	Completely report at least one of the five ACO-reported measures using the eCQM or Medicare eCQM collection type with CEHRT certified to applicable ONC criteria
FHIR API-supported quality reporting	Completely report at least one measure using CEHRT, and attest that the ACO used data from an HL7 FHIR-based API to support quality measurement
ACO-level metric attestation	Select and attest to one of three PY 2027 CEHRT metrics (see below)

The first two paths require complete reporting of at least one measure. The third path is an attestation route that operates at the TIN level.

PY 2027 CEHRT metrics (path 3)

For ACOs choosing the attestation route, three metrics are available:

Each metric carries its own TIN-level completeness requirement. 

ACOs can apply certain TIN-level exclusions without filing a separate CMS request — for example, a TIN composed solely of “special status” providers or one meeting specified hardship conditions. CMS requires the ACO to keep documentation supporting excluded TINs and provide it if audited.

The practical risk with path 3 is documentation. An ACO that attests without mapping the activity to each participating TIN — and without documenting its exclusions — has a compliance gap that only becomes visible during an audit.

What data completeness and TIN exclusion rules apply?

For each clinical measure submitted, ACOs must report on at least 75% of the APM Entity’s applicable beneficiaries who meet the measure’s denominator criteria. The data completeness threshold is the same standard that has applied in prior years.

Separately, CMS allows an ACO (beginning PY 2026) to exclude one or more participant TINs from a clinical data submission under specified circumstances:

• An unforeseen event outside the ACO’s control (such as a practice closure)
• A participant TIN whose specialty-use CEHRT does not support the measure

The ACO must still report on TINs representing at least 95% of the beneficiaries assigned to it before applying the measure specifications. The 95% condition gates TIN-level exclusions — it does not replace the 75% data-completeness requirement.

In practice, these two thresholds operate in sequence. First, the ACO must confirm that excluded TINs account for no more than 5% of assigned beneficiaries. Second, for the remaining TINs, each submitted measure must meet the 75% data completeness standard.

How does this differ from clinician-level MIPS PI?

The ACO-level CEHRT pathways are MSSP requirements — not the MIPS Promoting Interoperability measure set. Choosing a CEHRT path for the ACO does not automatically satisfy an individual clinician’s or group’s MIPS PI reporting obligation.

CMS’s enforcement discretion for the prior MSSP PI reporting requirement covers PY 2025 and PY 2026. That discretion does not erase the separate MIPS PI requirements for clinicians participating in an ACO.

The operational distinction is straightforward:

• The ACO determines its PY 2027 MSSP CEHRT pathway
• Each clinician or group separately confirms its own MIPS participation and PI reporting obligations

Treating the ACO’s chosen pathway as a blanket exemption from clinician-level MIPS reporting is a mistake that usually surfaces during the submission cycle — by which point the correction window is narrow.

What should MSSP ACOs prepare for PY 2027?

Preparation comes down to measure readiness, CEHRT path selection, and documentation discipline.

Your quality measures only work when the claims behind them are accurate — we handle both

MSSP quality reporting depends on clean claims, correct coding, and complete data. A denied claim, a coding error, or a credentialing gap in a participating TIN can cascade into a data-completeness shortfall that affects the entire ACO’s quality score. 

MedHeave operates as a full revenue cycle department inside your practice.

• First-pass claim rate of 90%+ with payer-specific scrubbing
• Credentialing and enrollment management with 95%+ approval rate
• Weekly and monthly reporting broken down by provider, payer, and location
• AAPC-certified coding reviews covering ICD-10, CPT, HCPCS, and modifiers
• Denial management with 80%+ overturn rate and 72-hour response windows

Frequently asked questions

Here are some commonly asked questions on this topic: