CMS recently published the FY 2027 Inpatient Prospective Payment System (IPPS) Proposed Rule which includes several proposed changes to the Hospital Inpatient Quality Reporting (IQR) Program and Medicare Promoting Interoperability (PI) Program for eligible hospitals (EHs) and critical access hospitals (CAHs). For the full text of the rule, see the Federal Register.

2027 IPPS Proposed Rule

Hospital Inpatient Quality Reporting (IQR) Program

New Measures

CMS is proposing to adopt the following three new measures in the IQR program:

• Excess Days in Acute Care After Hospitalization for Diabetes claims-based measure beginning with July 1, 2025 through June 30, 2027 performance period/FY 2029 payment determination
• Hospital Harm-Postoperative Venous Thromboembolism eCQM beginning with the CY 2028 reporting period/FY 2030 payment determination
• Advance Care Planning eCQM beginning with the CY2028 reporting period/FY 2030 payment determination

CMS is proposing to adopt the following five modified mortality measures beginning with the FY 2028 payment determination. These measures are modified to include adding Medicare Advantage patients and shortening the performance period from 3 years to 2 years:

• Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate Following Acute Myocardial Infarction (AMI) Hospitalization measure
• Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate Following Heart Failure Hospitalization measure
• Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate Following Pneumonia Hospitalization measure
• Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate Following Chronic Obstructive Pulmonary Disease (COPD) Hospitalization measure
• Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate Following Coronary Artery Bypass Graft (CABG) Surgery measure

Under this proposal, these modified measures would be adopted into the Hospital Value-Based Purchasing Program and removed from the IQR Program beginning with the FY 2032 payment determination.

Modified Measures

CMS is proposing to modify the following three measures beginning with the FY 2028 payment determination. These measures are modified to include adding Medicare Advantage patients and shortening the performance period from 3 years to 2 years:

• Excess Days in Acute Care after Hospitalization for Acute Myocardial Infarction
• Excess Days in Acute Care after Hospitalization for Heart Failure
• Excess Days in Acute Care after Hospitalization for Pneumonia

Removed Measures

CMS is proposing to remove three measures beginning with the CY 2028 performance period/FY 2030 payment determination:

• Venous Thromboembolism Prophylaxis (VTE-1) eCQM
• Intensive Care Unit Venous Thromboembolism Prophylaxis (VTE-2) eCQM
• Discharged on Antithrombotic Therapy (STK-02) eCQM

Reporting Requirements

CMS is proposing to require mandatory reporting of the Malnutrition Care Score eCQM beginning with the FY 2028 reporting period/FY 2030 payment determination. Additionally, CMS is proposing to establish a mandatory reporting policy to make hospital harm eCQMs mandatory after two years of reporting beginning with the FY 2028 reporting period/FY 2030 payment determination. Under this proposal, the Hospital Harm-Falls with Injury eCQM and the Hospital Harm-Postoperative Respiratory Failure eCQM would be mandatory to report beginning in CY 2028 reporting period/FY 2030 payment determination. The proposed Hospital Harm-Postoperative VTE eCQM would be mandatory to report beginning with the CY 2030 reporting period/FY 2032 payment determination. Lastly, CMS is proposing an update to the reporting of the Maternal Morbidity Structural measure beginning with the FY 2028 payment determination to require hospitals to identify the perinatal quality collaborative program they participate in.

Future Considerations

CMS is requesting comments related to potential use of the Emergency Care Access and Timeliness eCQM in the inpatient setting, potential use of the Adult Community-Onset Sepsis Standardized Mortality Ratio measure, and updating the scoring methodology associated with the Birthing Friendly Hospital designation to award designations by performance on the cesarean birth and the severe obstetrics complications eCQMs.

Medicare Promoting Interoperability (PI) Program

CEHRT Updates

CMS is proposing to update the definition of CEHRT for the Medicare PI Program based on updates proposed by the Office of the National Coordinator for Health IT (ONC). Specifically, CMS is proposing to remove the certification criteria for "family health history", "patient health information capture", "automated numerator recording", and "automated measure calculation" effective January 1, 2027. However, health IT developers that support hospitals participating in the Medicare PI Program will need to continue to support reporting of numerators and denominators for the Electronic Prescribing measure and Providing Patients Access to Their Health Information measure, regardless of the removal of the certification criteria.

CMS is also proposing to remove ONC Direct Review and ONC-Authorized Certification Body (ONC-ACB) Surveillance attestations beginning with the CY 2026 EHR reporting period.

New Measures

In alignment with the IQR Program, CMS is proposing to adopt two new eCQMs beginning with the CY2028 reporting period/FY 2030 payment determination:

• Hospital Harm-Postoperative Venous Thromboembolism eCQM
• Advance Care Planning eCQM

Modified Measures

CMS is proposing to modify the Electronic Prior Authorization measure. The measure description has been modified to: "For at least one medical item or service (excluding drugs) ordered during a hospital encounter that occurs within the EHR reporting period, the prior authorization is requested electronically through a Prior Authorization API using CEHRT". Under this proposed measure update, CMS has revised the phrase "using data from CEHRT" to "using CEHRT" as there are certified Health IT Modules available to be used to complete the action specified in the measure. The word "discharge" was changed to "encounter" as a prior authorization request may occur at any time during the hospital encounter. To give hospitals additional time before requiring the Electronic Prior Authorization measure, CMS is proposing to make the Electronic Prior Authorization measure optional and eligible for 10 bonus points for eligible hospitals and CAHs that attest "Yes" to the measure for the CY 2027 EHR reporting period. Further, CMS is proposing to require the Electronic Prior Authorization measure beginning with the CY 2028 EHR reporting period; hospitals and CAHs would be required to attest "Yes" or claim an applicable exclusion but the measure would not be scored.

Additionally, CMS is proposing to modify the reporting requirements for the Public Health and Clinical Data Exchange objective by adding the Unique Device Identifiers for Implantable Medical Devices measure beginning with CY 2027 EHR reporting period. To fulfill this measure requirement, CMS is proposing to allow hospitals to attest either "Yes" or "No" or claim an applicable exclusion. This would be one of seven measures required to satisfy the Public Health and Clinical Data Exchange objective.

Removed Measures

CMS is proposing to remove the Support Electronic Referral Loops by Sending Health Information and Support Electronic Referral Loops by Receiving and Reconciling Health Information measures beginning with the CY 2028 EHR reporting period. The other two HIE reporting options would remain unchanged requiring a Yes attestation to earn 30 points.

In alignment with the IQR Program, CMS is proposing to remove the following three eCQMs beginning with the CY 2028 reporting period/FY 2030 payment determination:

• Venous Thromboembolism Prophylaxis (VTE-1) eCQM
• Intensive Care Unit Venous Thromboembolism Prophylaxis (VTE-2) eCQM
• Discharged on Antithrombotic Therapy (STK-02) eCQM

If you have questions about your hospital reporting of eCQMs, Promoting Interoperability measures, or chart-abstracted measures, please contact us.