2027 IPPS Final Rule: Quality Programs – Part I

As we indicated in last week’s alert, the Centers for Medicare & Medicaid Services (CMS) has published its 2027 Inpatient Prospective Payment System (IPPS) final rule.  As part of that rule, CMS listed provisions that pertain particularly to various quality-related programs.  A CMS fact sheet summarizes these programs, and much of the below is based on that summary. 

Inpatient Quality Reporting Program

The Hospital Inpatient Quality Reporting Program is a pay-for-reporting quality program that reduces payments to hospitals that do not meet program requirements.  Hospitals that do not submit quality data or do not meet all Hospital Inpatient Quality Reporting Program requirements are subject to a one-fourth reduction in their Annual Payment Update under the IPPS.  

In the fiscal year (FY) 2027 IPPS final rule, CMS is finalizing the adoption of three new measures: 

• Excess Days in Acute Care After Hospitalization for Diabetes measure beginning with the FY 2029 payment determination 

• Hospital Harm-Postoperative Venous Thromboembolism electronic clinical quality measure (eCQM) beginning with the FY 2030 payment determination 

• Advance Care Planning eCQM beginning with the FY 2030 payment determination

CMS is finalizing the removal of three measures beginning with the FY 2030 payment determination: 

• Venous Thromboembolism Prophylaxis eCQM 

• Intensive Care Unit Venous Thromboembolism Prophylaxis eCQM 

• Discharged on Antithrombotic Therapy eCQM

CMS is finalizing modifications to three measures beginning with the FY 2028 payment determination.  Modifications 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

CMS is finalizing the adoption of five modified mortality measures, beginning with the FY 2028 payment determination, before moving the modified versions to the Hospital Value-Based Purchasing Program.  Modifications 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 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 Hospitalization measure 

• Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate Following Coronary Artery Bypass Graft Surgery measure

CMS is also finalizing changes to the data reporting and submission requirements for some eCQMs and structural measures, specifically: 

• Mandatory reporting for the Malnutrition Care Score eCQM beginning with the FY 2030 payment determination. 

• Establishing a mandatory reporting policy to make hospital harm eCQMs mandatory after 2 years of reporting beginning with the FY 2030 payment determination.  The proposed policy has been modified such that the data will be publicly reported on the Provider Data Catalog for the first year of mandatory reporting before publicly reporting on the Care Compare tool at Medicare.gov, including Hospital Star Ratings, beginning with the second year of mandatory reporting. 

• An update to the reporting of the Maternal Morbidity Structural measure beginning with the FY 2028 payment determination to identify the perinatal quality collaborative in which the hospital participates. 

Promoting Interoperability Program 

The Medicare Promoting Interoperability Program encourages eligible hospitals and critical access hospitals to adopt, implement, upgrade and demonstrate meaningful use of certified electronic health record technology (CEHRT). 

In this rule, CMS is finalizing policies to: 

Remove and revise certification criteria required for the Medicare Promoting Interoperability Program in alignment with proposals made by the Office of the National Coordinator for Health IT (ONC) in the Health Data, Technology and Interoperability: Assistant Secretary for Technology Policy (ASTP)/ONC Deregulatory Actions to Unleash Prosperity proposed rule (HTI-5 proposed rule) 

• Remove ONC Direct Review and ONC-Authorized Certification Body (ONC-ACB) Surveillance attestations beginning with the EHR reporting period in CY 2026 

• Remove, with modification to delay removal an additional year, the Support Electronic Referral Loops by Sending Health Information and Support Electronic Referral Loops by Receiving and Reconciling Health Information measures beginning with the EHR reporting period in CY 2029 

• Modify the Electronic Prior Authorization measure as an optional bonus measure for the EHR reporting period in CY 2027 and mandatory beginning with the EHR reporting period in CY 2028 

• Add the Unique Device Identifiers for Implantable Medical Devices measure to the Public Health and Clinical Data Exchange objective beginning with the EHR reporting period in CY 2027 

• Adopt two new eCQMs beginning with the FY 2030 payment determination in alignment with the Hospital Inpatient Quality Reporting Program (the Hospital Harm-Postoperative Venous Thromboembolism and the Advance Care Planning eCQMs) 

• Remove three eCQMs beginning with the FY 2030 payment determination in alignment with the Hospital Inpatient Quality Reporting Program (Venous Thromboembolism Prophylaxis, Intensive Care Unit Venous Thromboembolism Prophylaxis and Discharged on Antithrombotic Therapy eCQMs) 

We will wrap up the 2027 IPPS Quality provisions in our next alert.