From Compliance to Confidence

From Compliance to Confidence: Navigating the APP Reporting Evolution Through 2028

The CMS Web Interface has retired. Measure reporting has moved to electronic reporting. Is your ACO’s data infrastructure ready for the long haul?

 

The Reality Check

 

For years, ACOs relied on manual sampling and the CMS Web Interface. That bridge has been burned. Now, ACOs must report on all-payer data across the entire patient population.

 

But the goalposts are moving even further. As we look toward 2028, CMS is aligning the Universal Foundation of quality measures. This means:

 

2025: Mandatory transition to eCQMs/MIPS CQMs/MVP.

2026-2027: Increased focus on Social Determinants of Health (SDOH) data and health equity benchmarks.

2028: Full alignment of quality measures across all CMS programs, requiring a “single source of truth” for clinical data.

The EHR Obstacle

 

Most ACOs have discovered a painful truth: Clinical data is rarely “report-ready” at the source. The struggle to aggregate disparate data from multiple, non-standardized EHRs has left many organizations unable to meet the new reporting requirements. Common hurdles include:

 

Missing data elements in C-CDAs and QRDA formats.

Not all EHR vendors are fully FHIR ready.

No FHIR/CQL technical expertise to plan for the upcoming dQMs.

Lack of “All-Payer” data visibility.

Inconsistent coding across different clinical sites.

The inability to validate data before submission.

 

Moving to the Next Level with IMAT Solutions

 

At IMAT, we don’t just report data; we optimize it. While others struggle with the “how” of electronic reporting, IMAT helps you focus on the “results.”

 

Our Tools Take You Beyond Simple Submission:

 

Automated Data Aggregation: We ingest and normalize data from any EHR, ensuring your “All-Payer” population is fully captured.

Validation Engine: Identify unstructured content and fix data gaps early in the process.

The 2028 Vision: Our platform is built to adapt. As CMS introduces new measures and health equity requirements over the next three years, our modular system scales with you.

Full Clinical Transparency: Don’t just check a box; gain the clinical insights needed to improve patient outcomes and maximize shared savings.

 

Don’t let legacy data processes hold your ACO back from the next era of value-based care.

 

Get Ready for eCQMs: Get in Touch

How IMAT Can Help You Achieve Compliance

Here’s how our capabilities map to CMS’ Alternative Payment Model Performance Pathway (APP) quality reporting process:

Identify Eligible Population for the Quality Measure

Identify data sources for reporting across ACO participants, selecting appropriate collection types (eCQM or MIPS CQM) for each measure, and obtaining patient-level details from all participant TINs and CCNs based on measure specifications.

 

IMAT’s Capabilities:

We implement a six-step data ingestion process - connect, collect, validate, normalize, standardize, and index all data, no matter the source.

Patient details are obtained from all participating TINs and validated for measure compliance.

Patient Data Matching and Aggregation

Aggregate available patient data for accurate patient matching and deduplication, following organizational policies on patient identification. The eligible population for quality measurement will encompass 100% of the matched and deduplicated individuals.

 

IMAT’s Capabilities:

Our Enterprise Master Patient Index process is leveraged to resolve and manage patient identity.

All patient data is aggregated and deduped for the eligible population prior to measure generation.

For the eCQM collection type, 100% of the eligible population will be matched.

Apply Measure Logic

Apply specified measure logic to identify the eligible population meeting denominator criteria and determine numerator results, exclusions, or exceptions. For MIPS/Medicare CQMs, ensure performance data for a minimum of 75% of the eligible and matched denominator population. Use certified electronic health record (CEHRT) technology for eCQM collection to meet data completeness requirements.

 

IMAT’s Capabilities:

Quality measures are developed and implemented based on the clinical guidelines.

Our C3 data governance framework is leveraged for quality control and peer review to ensure we have the required data to meet the completeness requirements.

Submit to CMS

Submit measure performance to CMS in acceptable formats. CMS will calculate performance rates and data completeness from the submitted data. Each submission is considered complete for the included measure(s), and ACOs can resubmit within the reporting period, with any resubmission overriding prior ones. ACOs are encouraged to submit data early to address any technical issues.

 

IMAT’s Capabilities:

We are certified for both ONC HealthIT and CEHRT.

At any time prior to submission, results can be verified real-time.

Required QRDA III quality reports will be generated for submission.

Contact IMAT Today