2027 IPPS Proposed Rule At A Glance

CMS Just Released the 2027 IPPS Proposed Rule. Here’s What You Need to Know.

CMS released the FY 2027 IPPS Proposed Rule, and if you’re a quality leader, you probably already know what that means.

A lot of pages. A lot of changes. And a lot of pressure to figure out what actually matters.

The good news is this rule isn’t chaotic. It’s actually very consistent. CMS is moving in a clear direction, and once you see it, the rest of the rule starts to make sense.

Here are the biggest takeaways.

1. Quality Measurement Is Moving to Primarily eCQMs

This isn’t new, but it’s becoming unavoidable.

CMS is continuing the shift from claims-based measures to electronic clinical quality measures (eCQMs). The most important example is the transition away from PSI-based safety measures toward Hospital Harm eCQMs.

Performance is no longer based on what gets coded after the fact. It’s based on what gets documented in real time.

And those Hospital Harm measures are not staying optional. CMS proposed that after a short transition period, any and all Hospital Harm eCQMs will become mandatory.

Here’s a list of all eCQMs in IQR if finalized as proposed.

• Hospital Harm – Severe Hypoglycemia
  • Mandatory in CY 2026 and subsequent years.
• Hospital Harm – Severe Hyperglycemia
  • Mandatory in CY 2026 and subsequent years.
• Hospital Harm – Opioid-Related Adverse Events
  • Self-selected in CY 2026.
  • Mandatory beginning CY 2027.
• Hospital Harm – Pressure Injury
  • Self-selected in CY 2026 and CY 2027.
  • Mandatory beginning CY 2028.
• Hospital Harm – Acute Kidney Injury
  • Self-selected in CY 2026 and CY 2027.
  • Mandatory beginning CY 2028.
• Hospital Harm – Falls with Injury
  • Self-selected in CY 2026 and CY 2027.
  • Mandatory beginning CY 2028.
• Hospital Harm – Postoperative Respiratory Failure
  • Self-selected in CY 2026 and CY 2027.
  • Mandatory beginning CY 2028.
• Hospital Harm – Postoperative VTE (New Measure)
  • Self-selected in CY 2028 and CY 2029.
  • Mandatory beginning CY 2030.
• Malnutrition Care Score (MCS)
  • Self-selected in CY 2026 and CY 2027.
  • Mandatory beginning CY 2028.
• Advance Care Planning (ACP) (New Measure)
  • Self-selected in CY 2028 and CY 2029. Not Mandatory.

2. The “Easy” Measures Are Going Away

In 2028, CMS is proposing to remove several measures that hospitals have relied on for years, including VTE-1, VTE-2, and STK-02.

These measures are familiar. They’re stable. And for many organizations, they perform well.

That’s exactly why they’re being removed.

In their place, CMS is introducing more outcome-based measures, like the Hospital Harm Postoperative VTE measure and Advance Care Planning.

The result is fewer options and more complexity.

Hospitals won’t be able to rely on a handful of well-understood measures anymore. They’ll need to stand up new workflows, validate new data, and make more strategic decisions about what they report.

3. More Patients. Faster Feedback. Higher Stakes.

CMS is continuing to expand the inclusion of Medicare Advantage patients in all claims measures across multiple programs including IQR, HVBP, and HRRP.

At the same time, they’re shortening performance periods and updating risk adjustment models.

Those changes do a few things at once:

• Increase the number of patients included in your measures
• Make results more current
• Introduce more variability into performance

You’re being measured on more patients, with less lag time, and with less predictability in how performance will shift.

4. A New Mandatory Model: CJR-X

This is one of the most significant changes in the rule.

CMS is proposing a new mandatory bundled payment model called CJR-X, focused on hip and knee replacements.

This isn’t a pilot. It’s not limited to certain regions. It applies to nearly all acute care hospitals. And it doesn’t have an end date. If finalized, this would be the first mandatory nationwide program in a long time.

CJR-X introduces a 90-day episode of care and ties financial performance directly to both cost and quality. It includes both inpatient and outpatient procedures and includes your, now familiar, IP-THA/TKA PRO-PM.

If that sounds familiar, it should.

This model builds on the same concepts as TEAM, but it applies them in a focused, nationwide way.

It’s a clear signal that CMS is expanding their bundled payment model efforts.

5. The Same Measures Are Showing Up Everywhere

Another pattern in this rule is alignment.

The same measures are being used across multiple programs. You’ll see them in IQR, then in HVBP, then again in models like TEAM and CJR-X. And I expect more of this in the future as these Hospital Harm eCQMs become mandatory. CMS will likely throw these in all the programs they current have PSIs in.

This is also really evident for the THA/TKA PRO-PM which it feels like CMS puts in EVERY program.

In the future, you’ll be responsible for managing a shared set of measures that drive performance across multiple programs and payment models.

It also means you’ll be responsible for excellent data management. You’ve got to have a complete picture of your data and that data has got to be clean in order to make sure your new measures are an accurate depiction of the quality of care in your organization. In my experience, I don’t see that most organizations have this strategy fully built yet.

6. CMS Is Signaling What Comes Next

Some of the most important parts of the rule aren’t requirements yet. As always, CMS drops a few Easter eggs in the rule.

CMS is asking for feedback on digital quality measures (dQMs), including a Sepsis measure that would use a hybrid model combining EHR and claims data and incorporate a FHIR API submission instead of QRDA I file submission.

That’s a shift toward more automated, standardized, and continuous measurement which is the ultimate direction CMS wants to push the nation.

CMS is also considering expanding eCQM performance into public-facing programs, like the Birthing-Friendly Hospital designation. Instead of just using the maternal structural measure for the designation, they are considering adding the PC-02 and PC-07 eCQMs.

That means the measures you’re used to dealing with related to public reputation aren’t as important as getting these new measures up and running. These will eventually drive your public reputation and if you aren’t getting these ready now, you’ll be at a disadvantage compared to those hospitals who do.

So What Should You Do With All of This?

At a high level, this rule reinforces a few things.

• Measurement is becoming more clinically driven.
  • Performance depends on documentation and workflows, not just coding.
• The number and complexity of measures is increasing and eCQMs, especially Hospital Harm eCQMs, are a huge part of the increase
• New mandatory payment models position Quality as the gatekeeper to Cost

Quality leaders must manage the system that connects clinical care, financial performance, excellent data management, and public reporting. Quite a tall task.

Want the Full Breakdown?

We’ve only scratched the surface here. This rule introduces changes across nearly every major quality program, and the real impact comes down to how those changes affect your specific measures, workflows, and reporting requirements.

Inside Medisolv’s Quality Academy, our premium learning hub available to Medisolv customers, we’ve put together a complete, program-by-program breakdown of the proposed rule, including detailed analysis across IQR, PI, HRRP, HACRP, HVBP, TEAM, and CJR-X. You’ll also find practical guidance on what these changes mean and how your team can start preparing now.

If you’re responsible for quality reporting, performance improvement, or regulatory strategy, this is where you’ll want to go next  Access the full breakdown >>