FAH submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its draft proposal to transition from electronic clinical quality measures (eCQMs) to new Fast Healthcare Interoperability Resources (FHIR®)–based digital quality measures (dQMs). 

While FAH supports modernizing quality measurement and moving toward interoperable digital standards, we emphasized that this transition represents a major redesign of hospital reporting infrastructure and must be implemented carefully. We urged CMS to establish a clear, multi-year glide path with defined milestones, ensure CMS systems and vendor certification are fully ready before mandating use, and conduct broad real-world testing across diverse hospital types, including rural, safety-net, specialty, and community hospitals.

Read the FAH letter here.