Your quality reporting just got a fourth option

What the CY 2027 Proposed Rule Means for ACO Quality Reporting

The guideThe CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) closed for comment on September 14. CMS expects to issue the final rule in November, and it has already delayed PY 2025 financial reconciliation to that month so the finalized policies can be applied. This guide covers the quality reporting and CEHRT proposals that affect every Shared Savings Program ACO reporting the APP Plus measure set, and what to prepare for if they are finalized as written.

1.A new collection type: Medicare eCQMs

The headline change. Beginning PY 2027, ACOs would have a fourth way to report the five clinical measures in APP Plus: Medicare eCQMs.

What it is. A Medicare eCQM uses the standard eCQM measure specification but is calculated only on the ACO's assigned beneficiaries rather than the all-payer, all-patient population that traditional eCQMs require. Submissions would carry a distinct identifier so CMS can tell a Medicare eCQM apart from a regular eCQM.

Why CMS is proposing it. ACOs have told CMS for years that aggregating all-patient data across multiple EHRs and participant TINs is the biggest barrier to eCQM reporting. Medicare eCQMs are meant to give ACOs the digital reporting path without the aggregation burden.

How it would be scored. Flat benchmarks, the same treatment Medicare CQMs receive. ACOs choosing Medicare eCQMs would not qualify for the eCQM reporting incentive or the Complex Organization Adjustment.

Mixing is allowed. For each of the five clinical measures, an ACO could pick eCQM, MIPS CQM, Medicare CQM, or Medicare eCQM independently.

Where the ACO sits in the choice:

2.MIPS CQMs stay available

Under current policy, MIPS CQMs would have disappeared as an ACO option after PY 2026. CMS is proposing to keep the MIPS CQM collection type, and the MIPS CQM reporting incentive, available for PY 2027 and beyond. CMS's rationale is that forcing a collection-type switch would pull resources away from the transition to digital measurement.

For ACOs currently on MIPS CQMs, this removes the PY 2027 cliff. There is no forced migration.

3.Medicare CQM population aligns to the assigned list

CMS is proposing to revise the definition of a beneficiary eligible for Medicare CQMs so it matches the ACO's assigned beneficiary population. This builds on the CY 2026 changes and means Medicare CQMs and Medicare eCQMs would target the same patient list, which simplifies population management for ACOs using either.

CMS is also proposing that all Medicare CQM measures be scored on flat benchmarks for PY 2027 forward. Separately, Quality IDs 001, 134, and 236 reported via Medicare CQMs would be scored on flat benchmarks starting with PY 2026.

4.APP Plus shrinks to eight measures

CMS is proposing to remove two measures from APP Plus beginning PY 2027:

• Quality ID 305, Initiation and Engagement of Substance Use Disorder Treatment
• Quality ID 493, Adult Immunization Status

That leaves eight measures: five clinical measures reported by the ACO, two administrative claims measures, and CAHPS for MIPS.

5.TIN exclusions get a formal rule

Effective for PY 2026 and later, ACOs could exclude one or more participant TINs from a measure's submission when specific conditions apply, including:

• Unforeseen circumstances outside the ACO's control, such as a practice under a participant TIN closing unexpectedly
• A participant TIN whose CEHRT is specialty-focused and does not support the APP Plus measures
• Other circumstances CMS determines

The guardrail: the TINs the ACO does report must cover at least 95% of assigned beneficiaries before measure specifications are applied. The existing 75% data completeness requirement still applies to every measure the ACO submits.

6.Scoring policy for excluded measures changes

Today, a fallback scoring policy kicks in when any APP Plus measure is excluded or lacks a benchmark. CMS is proposing that for PY 2027 forward, the current fallback would apply only when the ACO's quality score is calculated on fewer than five measures, meaning four or more measures were excluded. A different scoring approach would apply in that case. The fallback would also no longer trigger simply because one required measure lacks a benchmark.

7.CEHRT use requirement replaces Promoting Interoperability reporting

This is the second major change. CMS is proposing to sunset the requirement that ACOs report all MIPS Promoting Interoperability measures. Starting PY 2027, an ACO would satisfy the CEHRT use requirement by completing one of three activities:

1. Report at least one clinical measure digitally. Completely report at least one of the five ACO-reported APP Plus measures via the eCQM or Medicare eCQM collection type.
2. Use CEHRT plus a FHIR attestation. Use CEHRT to support complete reporting of at least one of the five measures, and attest to using data from a FHIR-based API through a certified Health IT Module.
3. Attest to one ACO CEHRT use metric from a list CMS would set each year. For PY 2027, the proposed metrics are:
   • Electronic prescribing: at least one permissible prescription sent electronically via CEHRT from each participating TIN (TINs with fewer than 100 permissible prescriptions excluded)
   • Health information exchange: at least one provider from each participating TIN participating in bi-directional HIE exchange for at least one patient
   • Provider to patient exchange: at least one provider from each participant TIN giving at least one patient electronic access to their health information

ACOs could apply TIN-level exclusions under option 3 without filing a request, for TINs made up entirely of special-status providers or those meeting hardship conditions. Documentation must be kept for CMS audit, and failure to meet the requirement or to justify exclusions could lead to compliance action.

The public reporting requirement would also change: instead of publishing PI results, ACOs would publicly report which CEHRT use activity they chose.

Why this connects to Medicare eCQMs. Option 1 is where the two proposals meet. An ACO that reports even one measure as a Medicare eCQM would satisfy the CEHRT use requirement with no PI aggregation and no FHIR attestation. That makes Medicare eCQMs the lowest-effort route to CEHRT compliance for ACOs that cannot assemble all-payer eCQM data.

Source: CMS fact sheet on CY 2027 PFS proposed rule Shared Savings Program proposals, July 14, 2026. Proposals are subject to change in the final rule.

LEAD locked its first population without ever publishing who's in it

The headlineThe LEAD Model's first-cohort ACOs had until noon ET on September 8 to finalize participant drops, and CMS set the initial aligned beneficiary population on September 15. Both milestones passed the same way every LEAD milestone since the August 5 TIN commitment has passed: with no participant list, no press release, no Innovation Insight, and no update to the model page, which has not changed since August 18. For the ACOs that applied, that meant making the last irreversible roster decision before a ten-year model with no visibility into which peers, competitors, or overlapping TINs made the cut.

What is left on the LEAD calendar is short. The financial guarantee is due December 31, performance year one starts January 1, and CMS's own materials still describe the Medicaid-integration planning phase as running through December 2027 with two partner states yet to be named. ACO REACH ends December 31, and every REACH participant that is not moving to LEAD has to be in a Shared Savings Program agreement or out of Medicare accountable care entirely on January 1.

ACCESS's accepted list shrank by roughly a hundred organizations before the October start

The headlineWhen CMS first published the ACCESS Model's accepted-applicant page in August, the count read roughly 250 organizations. The page was revised on August 26 and now says "more than 150." CMS has not explained the change, but the page's own fine print does: inclusion on the list does not guarantee participation, and participation is contingent on completing Medicare enrollment, executing a Participation Agreement, and final CMS approval. The most plausible reading is that a meaningful share of the applicants CMS provisionally accepted in the spring did not clear those requirements before the model's rolling starts on July 5 and August 17.

The next start date is October 1, and applicants who applied after May 15 are slotted for January 1, 2027. ACCESS is a ten-year model built around technology-enabled chronic-condition management with a payer pledge behind it, and it is the Innovation Center's most visible rolling-entry experiment, so a trim of this size in the first quarter of operations is a data point on how much operational lift sits between provisional acceptance and actually taking risk.

Your clinicians' 2024 QPP scores are now public

The headlineOn September 10, CMS added calendar year 2024 Quality Payment Program performance information to the Provider Data Catalog and to the Medicare.gov Compare tool. For ACO participants that means the APP quality data your ACO reported for 2024 is now visible on individual clinician and group profiles that patients, referral sources, and payers can look up.

Public reporting is not new, but the timing is. The CY2027 proposed rule would also change what ACOs publicly report about interoperability, replacing Promoting Interoperability results with a statement of which CEHRT use activity the ACO chose, so the 2024 release is a preview of the reporting surface your quality program will be judged on.