October marks the start of the final 90 days of the 2025 performance year. It’s a high-stakes window for both QPP participants and ACOs. With deadlines clustering in October through December, the right moves now can determine whether organizations finish strong or fall behind.

Let’s take a look at the dates and deadlines for the last 90 days.

Key QPP Dates and Deadlines Key dates for MIPS and MVP participants include:

• October 3 - Final day to begin a 90-day Improvement Activity period; organizations relying on IA reporting must launch by this date to meet eligibility.
• December 1 - MVP registration deadline (8 pm ET); practices planning to report under an MVP must complete their election with CMS.
• December 2025 - MIPS eligibility is finalized for the 2025 performance year; QP determinations along with MIPS APM participation determinations are available on the Quality Payment Program Status tool.
• December 31 - End of the 2025 performance year and final day to submit hardship/exception applications; providers should confirm data completeness and file requests as needed.
• January 2–March 31, 2026 - Submission window; all performance data must be uploaded and finalized within this period to count toward scoring.

ACO Dates to Watch For ACOs preparing for 2026 participation, critical deadlines fall quickly:

• October 16 - CMS issues Phase 1 final dispositions; ACOs receive confirmation of participant lists, SNF affiliates, and assignment eligibility.
• October 17–28 - Phase 2 application submissions due (12 pm ET); organizations must upload governing body narratives, supplemental materials, and BIP/AIP documentation.
• November 7–14 - RFI window; ACOs must review CMS feedback and address any deficiencies to keep applications moving forward.
• December 4 - CMS releases final application dispositions; practices receive approval or denial notices across waivers and supplemental applications.
• December 5–11 - Signing Event; ACOs must electronically certify, sign agreements, and finalize details before the new agreement year begins.

Making the Most of the Final Quarter What makes Q4 uniquely challenging is not just the number of deadlines, but their overlap. Providers are simultaneously finalizing data completeness, managing application narratives, and preparing for submission readiness checks, all while running daily operations. It’s a period that demands prioritization, clarity, and disciplined execution.

With that said, three practices stand out for both QPP and ACO participants that might aid in easing deadline anxieties ahead of Q4:

• Prioritize early. Use October kickoff meetings to assign ownership and lock in internal deadlines ahead of CMS cutoffs.
• Audit proactively. Run internal “mock submissions” to identify weak spots well before the actual windows open.
• Leverage support. Use deadline trackers, reporting tools or partners, and internal checklists to maintain visibility and avoid last-minute scrambles in December.

The Final Stretch The last 90 days of the performance year are about execution. For providers, success depends on turning a crowded calendar into a structured plan, staying on top of key dates, running proactive checks, and maintaining disciplined workflows. With the right tools and approach, the final stretch becomes less about stress and more about strategy, positioning organizations for stronger outcomes in 2025 and beyond.

For those seeking added structure and support, solutions like Quantician can help simplify the process by tracking measures, surfacing data gaps, and streamlining submissions so providers can stay focused on high-quality care.