Comment on CMS-2026-1256-0002
Digital Quality Implementers Community (facilitated by Leavitt PartnersSupportAdvocacy
Summary: The Digital Quality Implementers Community (DQIC) supports CMS's goals of improving quality measurement and reducing administrative burden but advocates for a transition toward FHIR-native digital quality reporting. They specifically recommend prioritizing FHIR-based pathways over QRDA-based eCQMs to ensure long-term sustainability, equity, and reduced implementation costs for hospitals.
The Digital Quality Implementers Community (DQIC) thanks CMS for the opportunity to submit comments in response to CMS-1849-P.
DQIC is a multi-stakeholder community with experience implementing electronic Clinical Quality Measures (eCQMs), Fast Healthcare Interoperability Resources (FHIR)-based exchange, and Clinical Quality Language (CQL)-based measure logic. Our comments focus on feasibility, data availability, workflow implications, and long-term sustainability.
Across the proposals addressed, DQIC emphasizes the importance of aligning near-term policies with CMS’s broader direction toward interoperable, scalable digital quality reporting, while supporting clear transition pathways and reducing implementation burden.