HIMSS has recommended the creation of a pathway for the Centers for Medicare and Medicaid to move toward FHIR-enabled digital quality measures as the reporting vehicle for all CMS programs.

HIMSS sent public comments June 9 responding to the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2026 Rates; Requirements for Quality Programs; and Other Policy Changes (IPPS) proposed rule.

HIMSS identified a series of barriers to CMS adoption of dQMs and outlined recommendations that would facilitate a phased transition for all health sectors that support Medicare and Medicaid beneficiaries.

HIMSS recommendations include:

• Initiate merging the clinically nuanced data elements needed to facilitate dQMs that are presently found in the USCDI+ Quality Domain into the latest versioning of USCDI required for certified health IT
• Incorporate dQMs where current versioning of USCDI can support accurate and meaningful measurement into the CMS Inpatient Quality Reporting program as voluntary measures (with scoring bonuses available to eligible hospitals for choosing to report those measures)
• Provide funding support for phased projects and participation in measure development and testing participation by healthcare delivery organizations to address current measure gaps

HIMSS also noted several healthcare sectors that did not receive American Recovery and Reinvestment Act incentives for the adoption of certified health IT are not presently well positioned to utilize FHIR to meet reporting requirements, particularly long-term care hospitals and inpatient psychiatric facilities that are not tethered to integrated health systems.

HIMSS recommended CMS offer technical support and financial incentives to adopt FHIR-enabled APIs that would facilitate digital quality reporting.

HIMSS also responded to the proposed removal of social determinants of health quality measures from CMS reporting programs.

HIMSS noted that the removal of present measures like SDOH-1, Screening for Social Drivers of Health and SDOH-2, Screen Positive Rate for Social Drivers of Health is appropriate since both measures only assess the aggregate percentage of patients who have a health-related social need (HRSN) but do not parse the data into the specific HRSNs.

HIMSS endorses the replacement of the measures with more actionable SDOH measures like the Addressing Social Needs (ASN) quality measure. HIMSS also noted that merely removing the current measures does not reflect burden relief for providers as the healthcare sector has adopted the collection of SDOH data as a best practice, and developers have already made investments in creating the standardized tools needed by health systems to capture and utilize the data.

In other comments, HIMSS indicated support for CMS proposal to add voluntary measures with scoring bonuses for organizations to use FHIR-based APIs to report data to public health partners.