The Premier healthcare alliance appreciates that the Centers for Medicare & Medicaid Services (CMS) will delay the transition to new Medicare Shared Savings Program (MSSP) quality reporting requirements, as we recommended. However, we are concerned that CMS’ MSSP accountable care organization (ACO) measurement strategy fails to support the Innovation Center’s strategy refresh to move all Medicare beneficiaries into a total cost of care payment model by 2030. To achieve this vision, we must define the best approaches for assessing ACOs. We should not, as CMS’ policy requires, tie the ACO quality approach to fit within a Merit-based Incentive Payment System (MIPS) fee-for-service framework. Rather than placing undue burden on ACOs, CMS should focus on aligning value-based arrangements and quality reporting across payers.