HIMSS urges the Centers for Medicare & Medicaid Services to ensure new reporting mandates are paired with adequate data infrastructure, vendor readiness and clinical workflow integration to prevent undue administrative burden on providers.

HIMSS delivered the recommendation on the agency’s ongoing commitment to digital quality measurement and interoperability in formal public comments in response to the CY 2027 Physician Fee Schedule (PFS) Proposed Rule (CMS-1849-P).

Key recommendations from the HIMSS public comment letter include:

Remote Patient Monitoring (RPM/RTM) Reimbursement

HIMSS strongly opposed CMS’s proposal to eliminate reimbursement for third-party RPM and RTM services. Citing clinical research demonstrating the efficacy of RPM, HIMSS urged CMS to maintain coverage and instead leverage targeted audits and attestation requirements to combat waste, fraud and abuse.

Promoting Interoperability and Electronic Prior Authorization (ePA)

HIMSS supports aligning MIPS Promoting Interoperability requirements with Office of the National Coordinator certification criteria and adopting HL7® FHIR®-based APIs. However, citing unproven feasibility and implementation complexities, HIMSS recommended making proposed ePA measures voluntary with a bonus for CY2027 and CY2028 alongside an 18-month implementation window for substantive changes.

Transition to MIPS Value Pathways (MVPs)

HIMSS supports the long-term vision of specialty-aligned pathways and expresses concern over sunsetting traditional MIPS after CY2028. HIMSS recommends timing the mandatory MVP transition with processes that ensure every active MVP includes at least four fully validated eCQMs/dQMs and allowing single-group attestations for Improvement Activities and Promoting Interoperability.

Medicare Shared Savings Program (MSSP) ACO Flexibilities

HIMSS supports CMS proposals allowing ACOs to extend traditional MIPS CQM reporting through CY2027 and praises the 95% beneficiary threshold exclusion for ACO Participant TINs experiencing exceptional circumstances.

Digital Quality Measurement (dQM) Roadmap

HIMSS supports a two-year voluntary reporting period for FHIR-based dQMs aligned with a 100% quality score incentive for participating eligible clinicians, while urging CMS to address data quality, cost burdens and real-time dashboard capabilities.

HIMSS continues to advocate for policy solutions that advance digital health maturity while reducing clinician burnout and administrative friction.

For questions or further discussion regarding these comments, please contact Jonathan French, Senior Director of Public Policy and Content Development, at Jonathan.French@HIMSS.org