As 2025 winds down, the final 90 days of the performance year take on outsized importance. For practices, individuals, and Accountable Care Organizations (ACOs) participating in the Quality Payment Program (QPP), this window can make the difference between finishing strong or scrambling to catch up. With reporting season approaching, now is the time to tighten processes, confirm eligibility, and ensure every measure is accounted for.

Why the Final Stretch Matters The last quarter is often where providers either secure the data needed to demonstrate strong performance or risk falling short. From completing the required 90-day Improvement Activities period to ensuring patient surveys are submitted on time, these weeks are a checkpoint for the entire year’s work.

Key Priorities for the Last 90 Days Finalize Improvement Activities Improvement Activities require at least 90 consecutive days within the performance year. If your practice hasn’t yet completed its activity period, October is the final opportunity to launch. Use this time to verify that documentation (staff training logs, patient outreach records, or quality improvement project notes) is thorough and easily retrievable.

Confirm MVP Registration The deadline for registering under a MIPS Value Pathway (MVP) is December 1, 2025. This election cannot be retroactively applied, so practices interested in aligning measures under an MVP must act before then. Confirm your registration early to avoid technical issues, and ensure your chosen MVP aligns with the measures you’ve tracked throughout the year.

ACO-Specific Actions For ACOs in the Medicare Shared Savings Program (MSSP), Q4 is critical for aligning data submission strategies. This includes:

• Coordinating eCQM reporting across all participating practices to ensure consistency.
• Reviewing CAHPS survey progress, since survey data heavily influences overall quality scores.
• Conducting a gap analysis to identify missed patient encounters, screenings, or follow-ups that can still be addressed before year-end.

Audit-Readiness CMS may request proof of performance, so documentation is key. Practices should cross-check their records now, ensuring each submitted measure is backed by concrete evidence (e.g., screenshots, reports, or signed attestations). Establish a secure file system that centralizes this documentation for easy access if audited.

Patient Engagement Push Performance scores often hinge on preventive care and chronic condition management that can still be completed before December 31. Use these final months to:

• Call patients overdue for wellness visits, screenings, or labs.
• Close care gaps by scheduling follow-ups for chronic disease management.
• Document outreach efforts, even if patients decline, as CMS recognizes attempted engagement.

Tips to Stay Ahead

• Build a checklist of open measures and assign accountability across your team.
• Leverage EHR tools or registries to streamline data capture and submission.
• Schedule internal “mini-deadlines” in October and November so that December isn’t a last-minute scramble.

Making It Easier Navigating QPP requirements in the final stretch can feel overwhelming, but the right support simplifies the process. Whether you’re an individual clinician, part of a group, or managing ACO-level reporting, working with a CMS-Qualified Registry like Quantician can help ensure data is accurate, complete, and submitted with confidence.

Attending NAACOS October 8-10? Visit Table #20 to connect with Quantician and explore how data can be securely submitted to CMS while optimizing quality performance.