Another commenter suggested CMS maintain the existing policy for ACOs entering their first agreement period with a January 1, 2026 start date (that is, those ACOs should remain eligible for an additional two years under a one-sided model upon entering their second agreement period). A few commenters expressed a similar sentiment, suggesting that CMS apply the proposed policy only to new ACOs as currently participating ACOs entered the Shared Savings Program under the existing glide path and have been using shared savings to build infrastructure and capabilities necessary for risk-bearing arrangements
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Based on public comments, we acknowledge that the proposal to suppress the Electronic Case Reporting measure by excluding the measure from scoring could potentially impede and hinder a MIPS eligible clinician's, eligible hospital's, or CAH's ability to achieve that maximum points available under the MIPS Promoting Interoperability performance category or the Medicare Promoting Interoperability Program
