FAH Urges Careful, Phased Transition to FHIR-Based Digital Quality Measures in Comments to CMS

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FAH submitted its comments to the Centers for Medicare & Medicaid Services (CMS) concerning the draft proposal to transition from electronic clinical quality measures (eCQMs) to new FHIR-based digital quality measures (dQMs). While FAH supports modernizing quality measurement and moving toward interoperable digital standards, it emphasized that this transition represents a major redesign of hospital reporting infrastructure. Therefore, FAH urged CMS to establish a clear, multi-year glide path with defined milestones. Furthermore, they advised ensuring that both the CMS systems and vendor certifications are fully ready before mandating use, and conducting broad real-world testing across diverse hospital types, including rural, safety-net, specialty, and community hospitals. This highlights the operational complexity involved in adopting new digital quality measures.