Your APP Success

Thank you for choosing Mingle Health. As an ACO participating in value-based care and the Quality Payment Program (QPP), your success hinges on effectively measuring and reporting the quality of care you provide. The APM Performance Pathway (APP) is the required method for ACOs to report quality data to CMS as of the 2025 Performance Year.

The transition to the APP brings about new challenges for many ACOs. The APP requires a comprehensive approach to data collection, validation, and analysis and the shift can be burdensome for some organizations.

This page is designed to provide your ACO with the essential information, strategies, and resources needed for a successful APP submission with Mingle Health. On this page, we’ll cover:

• • Data requirements for the APM Performance Pathway
  • Measure collection types available for ACOs
  • Guidance on addressing data gaps
  • Promoting Interoperability (PI) requirements for ACOs
  • Additional Resources

To get started, we suggest watching our video presentation How to Succeed in MIPS, MVPs, and the APM Performance Pathway (APP) in 2025 below. This video contains important details about changes to the APM Performance Pathway in 2025 and can set you up for success this performance year.

After watching the video, scroll down for additional resources and information.

Now is also a great time to access our Quality Reporting for MSSP ACOs in 2025 PDF guide if you haven’t done so. Click the banner below to access the guide now:

The links below will redirect you to helpful APP resources and information from the Quality Payment Program website. We suggest saving or bookmarking these resources and reviewing them often to ensure your APP reporting project is on track with QPP guidelines.

2025 QPP Resources

2025 Learning Resources for All-Payer

2025 MIPS Guide to Using a QCDR or Qualified Registry

2025 Promoting Interoperability Quick Start Guide

2025 Medicare CQMs Specifications and Supporting Documents for Accountable Care Organizations Participating in the Medicare Shared Savings Program

The APM Performance Pathway is now the required method for quality reporting for all Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs). This pathway replaces the Web Interface as the means for ACOs to report quality data to CMS.

• Reporting Options: By the 2026 submission deadline, all ACOs must submit their quality data for the 2025 Performance Year via the APP using eCQM, MIPS CQM, or Medicare CQM collection methods.
• Measure Set: The APP uses a limited set of measures that will grow over time (see the “APP Plus” section below for additional details).
• Data Completeness: APP submissions are subject to the same Data Completeness Threshold that applies to MIPS submissions, which is set at 75% for the 2025 Performance Year.

To successfully construct an APP submission, ACOs must understand the data needed for the required measures and the accessibility of that data in their organization.

Data Collection Methods

Electronic Clinical Quality Measures (eCQMs): an all-electronic collection type available to ACOs to submit all-patient, all-payer data to CMS. eCQMs use end-to-end Certified EHR Technology (CEHRT) and rely on tested documentation workflows in your EHR systems.

MIPS Clinical Quality Measures (MIPS CQMs): a measure collection type available to Merit-based Incentive Payment System (MIPS) participants and ACOs to submit all-patient, all-payer data to CMS. MIPS CQM submissions can use end-to-end CEHRT or be supplemented by additional sources like manual abstraction or non-certified electronic systems.

Medicare CQMs: a temporary collection type available to ACOs to ease the transition from Web Interface reporting to APP reporting. Medicare CQMs use the same specifications as MIPS CQMs, but allow ACOs to limit their submissions to their Medicare patient population instead of all-patients, all-payers.

Data Sources

To understand data sources for APP reporting, it is helpful to take a moment to consider the role of numerators and denominators in quality reporting.

• Denominator: an accurate denominator is the foundation of any quality reporting effort. The denominator is a set of criteria that makes a patient eligible for any given measurement.
• Numerator: the numerator in a quality reporting effort is the evidence of the results of an intervention given to a patient identified as eligible for measurement.

Depending on the collection method that is the best fit for your organization, you may need to provide the following data to accomplish your APP submission.

Denominator Data: can be collected from 837 Claims Files, Practice Management System data, CMS Claims Line Feed (CCLF) files, or QRDA III files. Click here to access Mingle Health’s Denominator Specifications document.

Numerator Data: can be collected from Quality Data Codes (QDC), QRDA III files, QRDA I files, Continuity of Care Documents (CCD), Clinical Data Extracts, or Mingle Health Performance Spreadsheets. Click here to access Mingle Health’s Numerator Specifications document. 

The APM Performance Pathway (APP) Plus measure set is a requirement for ACOs as of the 2025 Final Rule. The measures in the APP Plus measure set align MSSP quality measurement with the Adult Universal Foundation measure set, and the required measures in the APP Plus measure set will grow in future years.

For 2025, ACOs are required to report the following measures from the APP Plus Measure Set:

• Measure 001 – Diabetes: Glycemic Status Assessment Greater Than 9% (formerly Diabetes: Hemoglobin A1c (HbA1c) Poor Control)
  • MIPS CQM Specifications
  • eCQM Specifications
• Measure 112 – Breast Cancer Screening
  • MIPS CQM Specifications
  • eCQM Specifications
• Measure 134 – Preventive Care and Screening: Screening for Depression and Follow-up Plan
  • MIPS CQM Specifications
  • eCQM Specifications
• Measure 236 – Controlling High Blood Pressure
  • MIPS CQM Specifications
  • eCQM Specifications
• Measure 321 – CAHPS for MIPS Survey
• Measure 479 – Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Eligible Clinician Groups

Future measures to be included in the APP Plus measure set:

• For 2026, colon cancer screening will be added
• For 2027, treatment of substance use disorder will be added
• For 2028, screening for social drivers of health and adult immunization will be added

Quality Performance Standards

For the 2025 Performance Year, ACOs that report the APP Plus quality measure set can meet the quality performance standard via one of three pathways:

• Achieve a health equity adjusted quality performance score that is equivalent to or higher than the 40th percentile across all MIPS Quality performance category scores, excluding entities/providers eligible for facility-based scoring.
• Achieve a quality performance score equivalent to or higher than the 10th percentile of the performance benchmark on at least one of the three outcome measures in the APP Plus quality measure set and a quality performance score equivalent to or higher than the 40th percentile of the performance benchmark on at least one of the five remaining measures in the APP Plus quality measure set.
• For ACOs in their first performance year of their first agreement period: meet the MIPS data completeness requirement on the four eCQMs/MIPS CQMs/Medicare CQM measures in the APP Plus quality measure set, receive a MIPS Quality performance category score, and administer the CAHPS for MIPS Survey.

Additionally, it is important to note that beginning in the 2025 Performance Year, measures submitted using the Medicare CQM collection type will be scored using flat benchmarks for their first two performance periods.

Identifying and rectifying data gaps is crucial for ACOs to ensure accurate quality reporting and maximize their shared savings potential. Data gaps can lead to an underestimation of performance, hinder the ability to meet quality standards, or cause your submission to fall below the 75% Data Completeness Threshold.

Identifying Data Gaps

• Proactively review your data to identify where information is missing or incomplete. Assess data availability across different EHR systems and member practices.
• Analyze numerator and denominator specifications for each measure to understand necessary documentation workflows and potential adjustments. Catalog your data locations within each specific system.
• Engage with your Mingle Health Consultant early and often to identify and correct gaps in your data flow. Your Consultant can help you understand gaps in member practice data and possibly identify exclusions, exceptions, and nuances to improve your data collection processes.
• Create a regular rhythm for data exchange between your organization and Mingle Health to process quality performance for further analysis. This allows for continuous monitoring and identification of gaps throughout the Performance Year.

Strategies for Addressing Data Gaps

• Ensure member practices document all data in easily extractable formats. If this strategy isn’t already implemented, meet with your Mingle Health Consultant to explore options for entering data in structured formats.
• Implement data validation processes to ensure the accuracy of extracted data. Compare a sample of data from your analysis to actual patient charts to confirm accuracy.
• Use your quality analyses from Mingle Health to drive performance improvement throughout the year. Develop patient lists in “Performance Not Met” status and implement strategies to address gaps such as documentation adjustments, chart reminders, or additional patient services.
• Address data governance contractually within your ACO to ensure all member practices contribute required data and work toward implementing Certified EHR Technology (CEHRT).

The Promoting Interoperability (PI) performance category focuses on patient engagement and the electronic exchange of information using Certified EHR Technology (CEHRT). For ACOs, understanding and meeting PI requirements is crucial for maintaining shared savings and optimizing performance.

• For performance years beginning on or after January 1, 2025, ACO participants, providers/suppliers, and professionals who are MIPS eligible clinicians, Qualified APM Participants (QPs), or Partial QPs must report the MIPS Promoting Interoperability performance category measures and comply with PI category requirements. This applies regardless of the Shared Savings Program track in which the ACO participates.
  • Participants must use EHR technology that meets the health IT certification criteria at 45 CFR 170.315 in the Code of Federal Regulations.
  • Data must be submitted for required measures in each objective for the same continuous 180-day period (or more) during the calendar year.
  • The EHR’s CMS identification code from the Certified Health IT Product List (CHPL) must be provided.

ACOs can submit Promoting Interoperability data at the ACO level. ACOs can also report Promoting Interoperability data at the individual or group level, where data will be aggregated and averaged into a single score for the ACO.

Here are additional resources to assist you with the APM Performance Pathway and the Quality Payment Program:

• The Mingle Health Guide to the 2025 Final Rule
• Mingle Health 2025 Promoting Interoperability Guide
• Quality Reporting: Numerator Data Specifications & Requirements
• Quality Reporting: Denominator Data Specifications & Requirements
• The Mingle Health Blog
• The Mingle Health YouTube Channel

New to the APP? Have questions?

We’re here to help. Please reach out to your Consultant or use the live chat to ask your questions. You can also call M-F 9am – 5pm ET: 866-359-4458