The Centers for Medicare & Medicaid Services (CMS) posted a user guide that outlines the quality reporting and scoring policies that apply to the Medicare Shared Savings Program (Shared Savings Program) for Accountable Care Organizations (ACOs) reporting via the Alternative Payment Model (APM) Performance Pathway (APP).

While the APP is optional for MIPS APM participants, it is required for all Shared Savings Program ACOs.  The final policies can be found in the CY 2021 Medicare Physician Fee Schedule Final Rule and in the 2021 Quality Payment Program Final Rule Resources.

What are the requirements for reporting under the APP?

Reporting requirements under the Shared Savings Program align with the requirements that apply to the APP under the Quality Payment Program. ACOs will only need to report one set of quality measures via the APP to satisfy the quality reporting requirements under both the Shared Savings Program and MIPS.

How will the ACO’s MIPS quality performance category score be calculated?

Each ACO’s MIPS quality performance category score will be calculated using the ACO’s performance on the measures reported under the APP, any applicable MIPS bonus points, and quality improvement points.

For the purpose of the Shared Savings Program, the MIPS quality performance category scores will be used to determine shared savings and shared losses, meeting the reporting requirements for both programs.

How will this affect ACO participants reporting outside of the ACO?

Starting with performance year 2021, Shared Savings Program ACOs are required to report quality data via the APP on behalf of their participants. If an ACO reports via the APP, then the ACO participants are not required to report quality separately to MIPS.

Where can I find more information?

To learn more about the APP, review the following resources:

  • APM Performance Pathway (APP) Toolkit (ZIP). Contains resources designed to help MIPS eligible clinicians successfully participate in the APP, including:
    • APM Performance Pathway for Shared Savings Program Accountable Care Organizations (ACOs) User Guide
    • 2021 APM Performance Pathway for MIPS APM Participants Fact Sheet
    • APM Performance Pathway for MIPS APM Participants in 2021 Infographic
    • 2021 APM Performance Pathway Quick Start Guide
    • 2021 APM Performance Pathway Reporting Scenarios
  • APM Performance Pathway Webpage


Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant. For faster responses, please consider calling during non-peak hours—before 10:00 a.m. and after 2:00 p.m. ET. Program hours are Monday to Friday, between 8:00 a.m. and 8:00 p.m. ET.

About Author

Back to top