The Medicare Shared Savings Program is entering a new phase, and for many Accountable Care Organizations (ACOs), the shift is more than operational. It is foundational.
For years, quality reporting under MSSP allowed for a level of flexibility. Organizations could rely on sampling, pulling a subset of patient records and completing manual chart abstraction to meet reporting requirements. While far from perfect, that approach made reporting manageable.
That model is now gone. With the transition to the Alternative Payment Model Performance Pathway, ACOs are required to report on their entire eligible population. That means all patients, across all payers, using electronic clinical quality measures and standardized submission formats.
This is not simply a regulatory update. It is a structural shift in how performance is measured, and it is exposing a reality many organizations have long suspected. The reality is that clinical data is rarely report-ready at the source.
From Sampling to Full Population Reporting
Under the previous model, sampling allowed organizations to focus their efforts on a limited dataset. Gaps could be addressed manually. Documentation could be reviewed and corrected before submission.
APP reporting removes that safety net.
ACOs must now aggregate, validate, and submit data across their full population, often spanning dozens of providers and multiple electronic health record systems. For many organizations, this represents a tenfold or even twentyfold increase in reporting volume.
At that scale, manual processes break down quickly.
More importantly, inconsistencies in how data is captured begin to directly impact performance. A diagnosis recorded differently across systems, or stored in unstructured notes instead of standardized fields, can mean the difference between receiving credit for a measure or missing it entirely.
The Data Problem Beneath Quality Reporting
The challenge facing ACOs is not that they lack data, but that their data is fragmented, inconsistent, and difficult to use.
Most ACOs operate across networks of independent practices, each with its own workflows, coding standards, and systems. Even when data is exchanged, it is not always aligned with the formats required for reporting.
When reporting depended on sampling, these issues could be managed through manual intervention. In a full population reporting environment, that is no longer feasible.
What emerges instead is a new requirement. Data must be complete, accurate, and standardized before it is ever used for measurement.
From Chart Chasing to Data Curation
This shift is driving a broader change in how organizations approach quality. The traditional model of chart chasing is being replaced by data curation.
Rather than tracking down individual records, ACOs must now build centralized data environments capable of aggregating and normalizing data from multiple sources. This includes resolving patient identities across systems, eliminating duplicate records, and ensuring that clinical data aligns with reporting requirements.
This is not just a technical exercise, but a shift in mindset. Data must be treated as a strategic asset, one that supports both reporting and care delivery.
Why This Matters for Financial Performance
For many health systems, MSSP represents one of the few opportunities to improve thin Medicare margins. But the path to those gains is becoming more complex.
CMS is accelerating the transition to two-sided risk, increasing both the opportunity and the exposure for participating organizations. Success will depend not only on clinical outcomes, but on the ability to measure and act on those outcomes in near real time.
Waiting until the end of the reporting period to understand performance is no longer viable.
Organizations need continuous visibility into care gaps, patient risk, and quality performance across their population.
Preparing for What Comes Next
The transition to APP reporting is only one step in a broader evolution. CMS is continuing to align quality programs and expand digital measurement frameworks, with increasing emphasis on interoperability standards such as FHIR and computable measures.
As this evolution continues, the organizations that succeed will be those that invest early in their data infrastructure. That includes:
· Aggregating data across clinical and claims sources.
· Normalizing data into consistent formats.
· Ensuring completeness and accuracy at the point of capture.
· Enabling real-time performance monitoring.
These capabilities are quickly becoming the foundation of value-based care.
A Digital Tipping Point
The shift from sampling to full population reporting represents a true tipping point for MSSP ACOs. It signals the end of manual workarounds and the beginning of a fully digital approach to quality measurement.
For healthcare leaders, the question is no longer whether data exists. It is whether that data can be trusted, used, and acted on at scale. Those that can answer that question with confidence will be the ones best positioned to succeed in the APP era and beyond.
Mark Coetzer
Mark Coetzer is VP of Business Development at IMAT Solutions, providers of health data intelligence platforms designed to help care organizations break down data silos, improve interoperability, and deliver real-time, actionable insights.
