4 APP Reporting Lessons Learned: How ACOs Can Prepare

The transition to APM Performance Pathway (APP) reporting has proven more challenging than most Accountable Care Organizations (ACOs) anticipated.

ACOs weighed which reporting path best fit their needs: MIPS Clinical Quality Measures(CQM), Medicare CQM (MCQM), or eCQM reporting. Regardless of the option selected, many ACOs significantly underestimated the scope and complexity of APP reporting—facing a dramatic increase in reporting volumes, complex EMR integrations, and year-round workflow demands.

The issue became clear when CMS released its final 2024 Medicare CQM patient lists. According to Healthcare Financial Management Association, only 16% of eligible MSSP ACOs used eCQMs/CQMs in 2023, indicating that most organizations found the transition to APP a "significant" or "very significant “operational challenge.

We’ve distilled key lessons learned from ACOs that navigated the first full year of APP reporting. Our article provides practical strategies to rethink how they collect, validate, and submit data—while meeting stricter deadlines and broader patient inclusion requirements.

Lesson #1: Expect APP Reporting Volumes to Multiply

One of the biggest surprises for many ACOs has been the sheer growth in reporting volume under APP. The misconception that reporting only applies to attributed Medicare beneficiaries has created significant strain on resources.

In some cases, ACOs saw their reporting populations double—or even triple—compared to prior years. For example, a mid-sized ACO with 60,000 attributed members ended up reporting on more than 120,000 Medicare beneficiaries.

Early quarterly patient lists can also be misleading. Q1 lists may appear manageable, but by Q3 or Q4, reporting populations often expand dramatically. The implications of this volume surge go beyond simple logistics. Workforce strain, data collection bottlenecks, and coordination challenges can quickly compromise reporting quality and completeness if not anticipated.

This growth trajectory means ACOs must plan capacity based on projected final volumes, not early-quarter estimates. Plan your staffing, systems, and workflows based on projected final volumes—not early estimates.

Key Takeaway: Don’t wait to get started. We have seen volumes double between Q1 and Q2. Make a plan to stay up-to-date so end-of-year reporting is manageable.

Lesson #2: Data Automation Is Essential for APP Reporting

Manual chart abstraction is no longer feasible for APP reporting, particularly when working with large patient populations. According to MDinteractive, automation—through Electronic Medical Records (EMR) integrations, lab data feeds, billing systems, and Health Information Exchanges—is critical to timely and accurate reporting, especially for non-assigned patients.

Automated data collection not only reduces manual labor but also improves measure performance by capturing more complete patient data—a critical advantage when reporting completeness directly impacts quality scores. Start by prioritizing EMR integrations, then expand to lab and billing systems. Manual processes should be limited to exceptions only.

Best practices include:

_{Integrate supplemental data feeds early to capture non-assigned patients.}

_{Validate data formats (like QRDA-1) regularly with your registry vendor.}

_{Use manual review only for exceptions—not as your core process.}

Key Takeaway: Data automation is no longer optional—it’s essential for completeness, accuracy, and efficiency.

Lesson #3: Make EMR Integration a Dedicated Role

Even with automation, coordinating EMR data feeds remains one of the most complex challenges in APP reporting. Data mapping, validation, and quality assurance are ongoing needs—not one-time tasks.

But according to AJMC, ACOs that established formal governance processes for EMR data quality show fewer reporting errors than those without such frameworks.

Common friction points to watch out for:

Incorrect Data Outputs: Many EMRs are not properly configured to generate the specific data elements required for current Clinical Quality Measure (CQM) specifications. Research consistently shows that custom configuration is often necessary to ensure accurate quality reporting.

This is not a simple task—it involves significant effort to validate that the data received from the EMR matches the source records and is correctly mapped to the appropriate fields within the output files. Without this rigorous validation process, reporting errors and measure inaccuracies are almost inevitable.

Data Blocking: Despite the Office of the National Coordinator for Health Information Technology's (ONC's) information blocking rules that went into effect in 2021, resistance persists. Many physicians still have trouble obtaining electronic health information from other providers or organizations, which could be a direct violation of Certified Electronic Health Record Technology (CEHRT) standards.

Measure Version Control: Some EMRs have not committed to supporting the current versions of the MIPS CQM measures required for APP reporting. Many EMR vendors require additional customization costs to fully support the latest CMS quality measure specifications.

The experience of one mid-sized ACO provides a cautionary tale: despite receiving assurances from their primary EMR vendor about quality measures support, they discovered in Q3 2024 that critical data elements for three key measures were not being captured in the expected format. The resulting scramble to implement workarounds cost them substantial additional IT resources and consultant fees.

Recommendations:

_{Assign dedicated staff for EMR data management.}

_{Establish formal governance processes for measure validation.}

_{Escalate unresponsive EMR vendors using CEHRT compliance leverage.}

Key Takeaway: Treat EMR coordination as a full-time responsibility to prevent costly data errors and measure inaccuracies. A coordinator’s role requires technical knowledge, relationship management skills, and a deep understanding of quality measures.

Lesson #4: Shift to Year-Round Workflows

The days of starting quality reporting in December are gone. Successful ACOs are adopting continuous, year-round workflows to manage APP reporting efficiently.

Implement quarterly targets. Track denominator eligibility, exclusions, and numerator compliance throughout the year to minimize end-of-year stress.

Tips for success:

_{Set quarterly completion goals.}

_{Track denominator eligibility, exclusions, and numerator compliance continuously.}

_{Audit data completeness throughout the year}

Essential Tracking Elements

Effective year-round workflows require tracking several key data elements:

• Member attribution status
• Data presence verification for each required data source
• Quality measure eligibility determinations
• Exclusion and exception documentation
• Numerator compliance evidence

Key Takeaway: Establish ongoing, quarterly workflows for data validation and submission to avoid last-minute challenges.

Common Pitfalls and Pro Tips

Beyond these four lessons, ACOs frequently encounter additional hurdles in APP reporting:

Missing Denominator Data: For non-assigned patients, claims data is often incomplete or unavailable, making denominator determination challenging. CMS data shows that denominator accuracy issues affect a significant portion of ACO quality measures in initial APP reporting.

EMR Data Transmission Issues: Even when data format specifications are correct, some EMRs fail to transmit actual results. One ACO discovered that their EMR integration was passing patient identifiers but not the associated clinical values for key measures—a problem that went undetected for months.

Vendor Cost Surprises: Many ACOs have encountered unexpected vendor charges for certain data outputs and workflows. Industry surveys show that many medical groups report paying additional fees to their EMR vendors specifically for quality reporting functionality.

CEHRT Compliance Leverage: ACOs should remember that CEHRT requirements provide leverage with reluctant EMR vendors. Under ONC regulations, CEHRT must support quality measures reporting—a fact that can be leveraged in vendor negotiations. Understanding these potential pitfalls allows ACO leaders to proactively build safeguards into their strategy.

Take Action on Your APP Reporting Strategy

The data from 2024 is conclusive: delayed planning directly correlates with lower quality scores. ACOs that waited until late in the year to begin APP reporting preparations consistently underperformed compared to those that adopted a proactive, year-round approach.

The urgency is real—ACOs must quickly define their strategy around:

_{Manual vs. automated data collection}

_{All patient, all payer eCQM vs. Medicare CQM vs. all-patient, all payer CQM reporting}

_{Staffing and resource allocation for quality reporting}

_{Technology investments for seamless data integration}

It's also important to understand that CMS requires ACOs to use a Qualified Registry vendor for quality reporting submissions—this may differ from your population health platform provider. Selecting a partner that offers both registry services and population health analytics delivers a strategic advantage with streamlining data integration, enhancing measure validation, and supporting performance improvement.

ACOs that partner with experienced population health analytics vendors are more likely to meet or exceed their quality goals than those managing the process alone. While the path forward maybe complex, you don't have to navigate it alone. Success depends on a knowledgeable partner and a well-defined strategy.

Ready to Optimize Your APP Reporting Process?

Our comprehensive solution combines Qualified Registry services with population health analytics to help ACOs:

✓ Automate data collection from multiple sources
✓ Validate EMR data quality and completeness
✓ Implement year-round quality workflows
✓ Improve measure performance and quality scores

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