Roles and Responsibilities


Key ACO Responsibilities 

  • Provide and maintain list of member TINs once per quarter

  • Provide and maintain list of provider NPIs once per quarter

  • Manage communication with member TINs / Member TIN outreach early and often during the performance period

  • Communicate with participant TINs about their obligation to upload data early and often during the performance period

  • Collaborate with Patient360 to determine the reporting capabilities of each member TIN within first 1-2 months of contracting with Patient360 (e.g., QRDAI/eCQM, CSV/CQM, CSV/MCQM)

  • Collaborate with Patient360 to coordinate delivery of data to Patient360 for each member TIN within first 1-2 months of contracting with Patient360

  • Monitor performance data for each member TIN throughout the reporting period: recommended at least bi-weekly

  • Monitor and remediate upload errors with participant TINs in SFTP server and/or Patient360 portal throughout the performance period

  • Ensuring data completeness requirements are met and all data is true and accurate/validate data 

  • Ensure all data is uploaded to Patient360 by February 28th following the performance period. 


Key Patient360 Responsibilities 

  • Initial provisioning and periodic update of ACO, member TINs, and NPIs in Patient360 platform 

  • Collaborate with ACO team to determine the reporting capabilities of each member TIN 

  • Collaborate with ACO team to configure delivery of data to Patient360 for each member TIN 

  • Assist ACO with monitoring performance data for member TINs and ACO throughout the performance period 

  • Assist ACO with final validation of data completeness

  • CMS data submission


Reporting Requirements 

The category information below is taken from the CMS MIPS Alternative Payment Model (APM) Performance Pathway (APP) Scoring Guide in the PY 2025 APM Performance Pathway (APP) Toolkit for the 2025 Performance Year (once available from CMS)


Quality

The quality category score represents 50% of the total APP score for an APM entity and is made up by the following measures of which Patient360 will submit the first 4 measures (001, 112, 134, & 236) on behalf of the ACO.  The remaining measures are the responsibility of the ACO.


Quality IDQM TitleCollection Type
001Diabetes: Hemoglobin A1C (HbA1c) Poor Control

eCQM (CMS122v13)

MIPS CQM 

Medicare CQM

112Breast Cancer Screening

eCQM (CMS125v13)

MIPS CQM 

Medicare CQM

134

Preventive Care and Screening: Screening for Depression and Follow-up Plan

eCQM (CMS2v14)

MIPS CQM 

Medicare CQM

236Controlling High Blood Pressure

eCQM (CMS165v13)

MIPS CQM 

Medicare CQM

321CAHPS for MIPS (Groups & APM Entities only)

CAHPS for MIPS Survey


479 

Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Eligible Clinician Groups

Administrative Claims


Promoting Interoperability 

The Promoting Interoperability performance category is weighted at 30% of the MIPS final score for the APP. 

Promoting Interoperability data can be delivered to Patient360 for any, all or none of an ACOs member TINs and submitted to CMS at the group level or ACO level if desired.  It is the responsibility of the ACO to obtain eligibility status of each member TIN for the PI category and if desired, to formally request, via P360 order form (insert link here to the order form) if P360 will be submitting PI data on behalf of the ACO and/or any of its member TINs.  


Cost 

The cost performance category is weighted at 0% of the MIPS final score for the APP, because all MIPS APM participants are already responsible for costs under their APMs 


Improvement Activities 

MIPS APM participants reporting the APP don’t need to submit any data for the improvement activities performance category for the 2025 performance period. Each year, we’ll assign a score for the improvement activities performance category for each MIPS APM. All MIPS APM participants who report the APP in 2025 will automatically receive 100% for the improvement activities performance category score (20 out of 20 points towards your MIPS final score).