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Policy Snapshot

February 16, 2024

To be eligible for shared savings and shared losses through the Shared Savings Program, an ACO or third-party intermediary acting on behalf of the ACO must submit quality reporting data via the Alternative Payment Model (APM) Performance Pathway (APP). The data submission period opened on January 2, 2024.


Data submission will close at 8:00 PM ET on April 1, 2024. When submitting quality data for the Electronic Clinical Quality Measure (eCQM)/Merit-based Incentive Payment System Clinical Quality Measure (MIPS CQM) measure set, sign into the Quality Payment Program (QPP) website and select “Start Reporting” on the main page or “Eligibility & Reporting” from the left-side navigation bar. Then, on the Reporting Options page, select “Start Reporting” on the APP reporting option. Next, select “Report APP” on the confirmation prompt to upload the quality data files.


Before uploading or submitting data files, ensure they are tagged as an APP submission. To tag your ACO’s data file correctly, ACOs must do the following depending on the file type:

  • For QPP JSON files, “category” must be labeled as “quality” and “programName” must be labeled as “app1” at the measurement set level. For more information, refer to Tutorial: APP Submissions in the QPP Developer Preview Environment Documentation.
  • For Quality Reporting Document Architecture (QRDA) III files, your file must have the correct file naming convention of “MIPS_APP1_APMENTITY” as the CMS Program Name. For more information, refer to the CMS Implementation Guide for Quality Reporting Document Architecture Category III.


Please note that if the quality data file is not correctly tagged as an APP submission, the system will still indicate that the file has been uploaded successfully, but there will not be a quality data file on the APP Reporting Overview page. Instead, the file will automatically be submitted and scored as a traditional MIPS submission if nothing else is selected, and it will not be eligible for purposes of the Shared Savings Program. If this happens, you must resubmit the file with the correct flags as listed above, and ACOs can then reverify the submission in the APP Reporting Overview page.


For a comprehensive reporting submission walk-through, refer to the 2023 Alternative Payment Model (APM) Performance Pathway (APP) Data Submission User Guide.