Why the CY 2027 PFS Rule Gives Shared Savings ACOs Several Digital On-Ramps Instead of One ePA Mandate: APP Plus, Medicare eCQMs, the 95/75 Gates, Three CEHRT Paths, and the FHIR dQM Roadmap

The most expensive misread of the CY 2027 PFS rule: people see ‘ePA’ near ‘ACO’ and think CMS just mandated electronic prior auth for Shared Savings orgs. It did not. Here is what actually happened.

CMS built several on-ramps toward a digital ACO model, not one switch. Some are firm 2027 proposals. Some are RFIs about 2028. Some live in MIPS or the Ambul…