July 23, 2026
The ruling upheld a previous decision that pharma companies cannot impose rebates without HHS Secretary approval.
This article was originally published on Fierce Healthcare.
The industry's trusted authority on overturning denials and payer audits — equipping providers with the expertise, resources, and community to challenge unfair practices, recover rightful revenue, and drive lasting change in healthcare reimbursement.
AHDAM speaks for the people doing the work — pushing back on payer practices that erode reimbursement, surfacing patterns across hospitals, and partnering with policy bodies to drive change.
119+ tip sheets, templates, policies, and 50 state-by-state legal snippets — searchable by denial type, payer, and clinical scenario. Two decades of practitioner-tested guidance.
Live sessions and on-demand recordings from the appeal professionals who've done it. Clinical validation. DRG downgrades. Prior auth strategy. Ask-the-experts Q&A built in.
AHDAM Appeal Management Certification — the credential that proves you can do this work. Curriculum, exam, continuing education, all in one pathway.
AHDAM is proud to announce a strategic partnership with Hyve Health. Our shared mission is to strengthen the healthcare community's ability to prevent manage, and overturn insurance denials.
HYVE brings advanced analytics and tranparency tools, like the Payer Vitality Scorecard™, empowering providers to track and respond to shifting payer behavior.
Partners →
PayerWatch is on a mission to ensure every hospital in the U.S. is fully capable of defending themselves against egregious payer behavior. That's a mission we at AHDAM can get behind!
Through sophisticated software and world-class appeal solutions PayerWatch is holding payers accountable and protecting provider revenue like no one else in healthcare today.
Partners →AHDAM is the only place I've found where the appeal letters, the legal precedent, and the people who've actually overturned these denials all live in one room.
I've written hospital appeals for 15 years. By far the most practical training I've ever taken — clinically grounded, legally informed, and immediately useful Monday morning.
The Minnesota ACDIS chapter learned an enormous amount. Conversational, candid, and packed with strategy we can deploy that day.
Founded AHDAM to put practitioner intelligence in every appeal professional's hands. Two decades in healthcare denial & appeal management.
Senior Fellow in Hospital Medicine. Leads clinical & physician-advisor programming, peer-to-peer strategy, and the certification curriculum.
AHDAM's board brings together healthcare attorneys, physician advisors, and revenue cycle leaders from health systems nationwide.
Become a member, get certified, or ask the appeal experts — three ways into the AHDAM community.
July 23, 2026
The ruling upheld a previous decision that pharma companies cannot impose rebates without HHS Secretary approval.
This article was originally published on Fierce Healthcare.
Author: Ronald Hirsch, MD, FACP, ACPA-C, CHCQM, CHRI | July 22, 2026
Lots of topics for today. First, last week I was discussing a hospital’s Program for Evaluating Payment Patterns Electronic Report (PEPPER) results with them and noted that they were a high outlier for one-day inpatient admissions. Their number was small, but nonetheless, they exceeded the 80th percentile. But this was not news to them, as they had just received a letter from their Medicare Administrative Contractor (MAC) informing them that they were selected for an audit of their short-stay inpatient admissions.
As you may recall, the Centers for Medicare & Medicaid Services (CMS) gave this duty back to the MACs from the Quality Improvement Organizations (QIOs) late last year, and it appears that the MACs are finally ready to start auditing. Of course, my hope is that they can interpret the Two-Midnight Rule better than they did back when these audits first started in 2014, after which CMS had to reassign the duty to the QIOs.
Speaking of the PEPPER, I am having continuing frustration with the new iteration. In light of the resumption of the short-stay audits, I took a close look at the data reported on the PEPPER to try to figure out what can be considered a normal rate of one-day inpatient admissions. Now, before you protest, I know every hospital is different, and if you get the status right on every patient, your short-stay rate is what it should be. But we all know that people like benchmarks.
And lo and behold, there was a significant problem. In the PEPPER for the fourth quarter of 2025, it states that the national 80th percentile for the last 10 quarters for one-day inpatient medical DRG admissions was about 10 percent. But in that same table, in the next PEPPER for the first quarter of 2026, that same 80th percentile for the previous 10 quarters was indicated as about 15 percent. That’s a huge difference.
And when I asked CMS, they responded that there was a “methodology refinement.” Now, I could understand an adjustment of a percentage point or two, but errors like this by the new CMS PEPPER contractor really call into question the legitimacy of all the data. Now, I wonder if it is better to have bad data than no data.
Next, Humana recently published a policy change indicating that they will start denying payments under their readmission program for patients who return and are placed as outpatient with observation, in addition to patients who are readmitted as inpatients. Now, to give them credit, they do note that they will review to determine if the return was related or preventable.
But if you start seeing such denials, I would ensure that they were reviewed per their policy. If the hospital’s processes or lack of proper discharge planning did not result in the return, why should you be forced to relinquish payment? Does Humana take the blame when one of their enrollees is readmitted because their contracted home care agency does not provide the patient the necessary home care? I think not.
Finally, let me share, without further comment, an appeal saga that a case manager experienced. “We received a denial from an MA (Medicare Advantage) plan. We consulted with the patient at the bedside, and the patient and the admitting physician signed the AOR form. We submitted all documentation to them as a Fast Appeal. When we followed up on their receipt, they stated that they received it as a Standard Appeal. We were transferred around, sometimes to the same person, and we were eventually told that the account has been reclassified as a Fast Appeal.”
She went on to note that “a few days later, we followed up again and were told that, since there is no AOR form, it is a Standard Appeal. We asked them to open the document while we were on the phone, and lo and behold, the AOR form is there.
They are now stating that we must resubmit everything again as a Fast Appeal. The patient has since been discharged, of course.”
This article was originally published on RACmonitor.
July 22, 2026
The companies say providers will receive quicker, first-time approvals through the partnership, ultimately giving members quicker care access.
This article was originally published on Fierce Healthcare.
July 22, 2026
The Trump administration will appeal a Georgia court ruling that led it to broadly recalculate insurers’ Medicare Advantage star ratings scores for 2026.
This article was originally published on Fierce Healthcare.
July 22, 2026
Cigna Healthcare is taking steps to significantly expand its personalized care management programs, leaning on AI to identify risks sooner and simplify the patient journey.
This article was originally published on Fierce Healthcare.
Author: Rachana Pradhan | July 21, 2026
Marie Noon takes eight medications a day. One keeps her heart rate from spiking to avoid a stroke. One prevents debilitating headaches. Another ensures she doesn’t retain excess fluid.
More than a decade ago, Noon said, she was diagnosed with adult-onset Still’s disease, a rare type of inflammatory arthritis that can cause rashes, debilitating pain, and fevers. The disease upended her life.
She had been living a typical suburban life in Michigan, shuttling her two kids to activities like cheerleading, choir practice, and track. She was active in the PTA. She managed a bank.
She went from that to crawling to the bathroom because she was in so much pain, “just crying all day long” from being so sick.
Noon, who is disabled, said she couldn’t work for eight years — a time marked by hospital stays that stretched for weeks.
“I honestly thought I was going to die,” Noon said.
So it was a shock when Michigan denied her application for Medicaid benefits last year after she lost private insurance. Worse yet, it came down to an IT error, according to an attorney who helped Noon overturn the denial.
“I can’t afford my medical care. I have to have insurance,” said Noon, who has returned to working.
Deloitte, a multibillion-dollar global consulting firm, has operated Michigan’s Medicaid eligibility system under contracts worth roughly $768 million since 2006, according to contracts reviewed by KFF Health News. Nationwide, Deloitte dominates this important slice of government business: At least 25 states have awarded the company contracts to build or run computer systems that control access to safety net benefits such as Medicaid.
Michigan’s system has incorrectly directed people with disabilities into skimpier benefits that cover limited care or has denied coverage completely, a KFF Health News investigation found. Similar problems were at the center of a class-action suit in Tennessee, court documents show, and have occurred in Texas, according to interviews and state records.
The KFF Health News investigations are based on statements from state officials, allegations and declarations in court documents, emails obtained through public records requests, state government information provided to Medicaid enrollees and applicants, and interviews with attorneys and patients or their caregivers.
In an emailed statement, Deloitte spokesperson Karen Walsh said it found “no system anomalies causing routine denials of Medicaid for people with disabilities.”
“There are many reasons why someone may no longer be eligible for a benefit they once received or believe they deserve,” Walsh said. “All of the eligibility systems we support are owned by the states and built to their unique specifications. We will continue to work at the direction of our state clients.”
Lynn Sutfin, a spokesperson for Michigan’s Department of Health and Human Services, said it “is not aware of any widespread or systemic issues” within Bridges, Michigan’s eligibility system for Medicaid, SNAP, and other benefits, “related to disability‑based eligibility pathways.”
Since 2006, Deloitte’s contracts with the state have said the company is responsible for development, implementation, maintenance, operations, and enhancements to the Michigan system.
Computer system problems foreshadow trouble as states prepare to roll out the most significant and complicated changes to their Medicaid programs in years. Those changes, dictated by President Donald Trump’s landmark One Big Beautiful Bill Act, have states rushing to update their Medicaid computer systems.
Nationwide, roughly 15.5 million people on Medicaid have a disability, according to KFF.
“When these administrative systems get overloaded, everyone gets impacted,” said Pamela Herd, a University of Michigan professor who researches bureaucratic obstacles to accessing government benefits. “The systems are going to be really, really strained.”
In Michigan, Noon was eligible for Medicaid through a program that provides coverage to disabled adults who work. But the state’s computer system didn’t register that she is disabled and said she earned too much to qualify, according to documents reviewed by KFF Health News and interviews with Noon and Anastassia Kolosova, a disability rights attorney who helped her.
Without Medicaid coverage, Noon paid hundreds of dollars out-of-pocket for prescriptions, after scrounging for discount coupons. She takes some of the drugs twice a day.
Without them, “I’m toast,” she said. It was stressful “not knowing if my medicine’s going to be $50 or $500 this month, because it changes constantly.”
Noon said her doctor agreed to fewer visits to avoid medical bills.
“It was kind of a nightmare,” Noon said.
‘I Just Wanted To Give Up’
Medicaid, a safety net health program jointly run by the federal government and states, covers roughly 67 million people with low incomes or disabilities. State governments rely on companies like Deloitte to design and operate computer systems that assess whether people qualify for Medicaid or food aid through the Supplemental Nutrition Assistance Program, commonly known as food stamps.
That technology has a history of errors that deprive eligible people of benefits, earlier KFF Health News investigations have shown. As reported previously, Kenneth Smith, a Deloitte executive who leads its national human services division, said Medicaid eligibility technology is state-owned and agencies “direct their operation” and “make decisions about the policies and processes that they implement.”
“They’re not Deloitte systems,” he said, noting Deloitte is one player among many who together administer Medicaid benefits.
States are under immense pressure to update their eligibility systems on a tight schedule to adhere to requirements in the Republicans’ sweeping 2025 tax and spending law. Companies including Deloitte, Accenture, and Optum are being paid millions in taxpayer funds to make the changes, which are projected to strip Medicaid from roughly 7.5 million people and SNAP from 2.4 million people by 2034.
Many coverage restrictions in the new federal law don’t apply to seniors, children, or people who are disabled, such as Noon. Nonetheless, the law’s demands on state agencies and the computer systems they oversee will disrupt benefits, advocates for Medicaid enrollees and other healthcare experts said in interviews.
The same systems also need to correctly classify why someone is eligible for Medicaid — and therefore which rules and restrictions apply.
The law’s SNAP restrictions began to take effect in 2025, and major Medicaid provisions begin later this year, generally after the midterm elections.
Kolosova is a supervising attorney with Disability Rights Michigan, a legal advocacy organization for people with disabilities. She said she has been unable to get a meeting with Michigan officials to understand the underlying problem that deprived Noon of health coverage.
Anastassia Kolosova, a supervising attorney with Disability Rights Michigan, helped Noon navigate the complicated process to obtain safety net health insurance through Medicaid. Kolosova says she has seen multiple wrongful coverage denials and fears problems will soon get worse because of changes required by federal law. (Kate Wells/KFF Health News)
State records show Deloitte has held contracts for at least 14 years for Bridges, Michigan’s eligibility system for Medicaid, SNAP, and other benefits. In its attempts to secure more business, the company often cites its nationwide footprint in Medicaid operations.
“Deloitte understands Bridges,” and its history in Michigan makes the company “the ideal vendor,” the firm said in its bid documents. Given Deloitte’s work on similar systems in 31 other states, the firm said, “Michigan benefits from our technical expertise drawn from across the nation.”
But advocates who work with people with disabilities say Michigan’s computer system has failed to recognize when certain adults should receive Medicaid benefits.
Problems aren’t unique to the Great Lakes State. Medicaid beneficiaries who brought a class-action lawsuit against Tennessee in 2020 said the state’s Deloitte-built system “does not reliably test for eligibility” for several categories of people with disabilities. The firm’s contract in Tennessee is worth $1.12 billion over a decade.
A federal judge in 2024 sided with the Medicaid beneficiaries, ruling that Tennessee violated federal law and the U.S. Constitution. The lawsuit does not name Deloitte as a defendant.
In Michigan, a 2010 report from the state’s Office of the Auditor General said government agencies “did not provide effective project administration” and failed to ensure that the state could “independently maintain and operate Bridges” because “the contractor did not transfer knowledge and skills” to state officials, according to the audit.
The auditor’s report said that, as a result, Deloitte’s original contract — valued at roughly $70 million — ballooned by $50 million over the initial cost, a 71% increase. State records show Michigan would go on to add millions more, bumping the cost of Deloitte’s initial contract to $124.1 million.
The audit said maintaining the contract would result “in significant additional costs.”
Sutfin said that “the state is now fully capable of operating and maintaining Bridges independently.”
Deloitte’s latest contract in Michigan — worth $197.4 million — is set to expire in 2030.
Noon applied for Medicaid in August, she and Kolosova said. In September, the Michigan Department of Health and Human Services sent a notice denying her coverage, citing incorrect income information and stating she wasn’t disabled, according to Kolosova and state documents reviewed by KFF Health News.
Noon said that when she called the state for help, state workers “didn’t know anything about” the Medicaid program she had applied to, Freedom to Work.
“I can’t tell you how many times I just wanted to give up,” she said.
For some people with disabilities, Medicaid is supposed to count only half their earnings when assessing whether they should receive benefits. That didn’t happen. Kolosova said she thinks Michigan’s eligibility system didn’t identify Noon as disabled, even though the state “already had all the information they needed” to show she was.
By failing to recognize her disability, the state used the wrong income formula and said Noon earned too much to qualify for Medicaid, she added. Deloitte and Michigan declined to respond to a detailed list of questions about Noon’s experience.
Kolosova said Disability Rights Michigan has seen a growing number of calls from people about Freedom to Work benefit denials. “Maybe two or three a month,” she said.
“There’s something wrong with the system if they’re relying on individual caseworkers to catch this,” Kolosova said. “The system needs to work.”
Noon at home with her dog, Ziggy. Despite being eligible for Medicaid, she was denied coverage in 2025 because of an error with the state’s benefits system. It took months of pushback before the state reversed its mistake. Even as a “tech-savvy” former bank manager, she says, she wanted to give up several times along the way. (Kate Wells/KFF Health News)
Enrolled in the Wrong Coverage
Noon’s experience isn’t the first time in recent years that people with disabilities have been denied benefits by Deloitte-run eligibility systems.
In Texas in 2023, Lilly Livingston, who has Down syndrome and is now 22, was abruptly cut off from Medicaid benefits, according to Livingston’s mother, Marie. She has undergone numerous surgeries to reconstruct her severely misaligned jaw, which caused sleep apnea and impaired her speech and chewing ability. She relied on an array of Medicaid services, including speech and occupational therapy.
When Livingston lost benefits, she was wrongly enrolled in Healthy Texas Women, a limited program that provides breast and cervical cancer screenings and family planning services.
“Trying to fix that was a nightmare,” Marie Livingston said.
Terry Anstee, an attorney with Disability Rights Texas, intervened.
In a September 2023 email with the subject line “URGENT,” Anstee begged a Texas Medicaid eligibility worker for help.
Some unknown “error” had occurred and stripped Livingston of her benefits, Anstee said in an email he sent to a state Medicaid staffer. “Lilly has had 2 major surgeries, and her recovery is contingent on Medicaid.”
It was clear that Livingston qualified for Medicaid through multiple paths, Anstee said: “It never made any sense.”
Deloitte declined to respond to a detailed list of questions about Livingston’s case. Jennifer Ruffcorn, a spokesperson for Texas Health and Human Services, confirmed that Livingston was erroneously enrolled in Healthy Texas Women. However, Ruffcorn said, Livingston did not experience a lapse in Medicaid coverage in 2023.
Anstee disputed the state’s characterization: “A glance in the system by a Texas HHS press officer or other staff 3 years after the fact may not tell the full story or show the issues that Ms. Livingston endured in August and September 2023. Ms. Livingston experienced lapses in coverage.”
The problem Livingston encountered in Texas was also reported in Michigan.
In 2024, mental health services advocates in Michigan raised red flags about a similar error: People with disabilities were being enrolled in a limited Medicaid program covering sexual health and family planning services. Plan First covers only services such as birth control and treatment for sexually transmitted infections. It doesn’t provide the comprehensive coverage that people with disabilities require.
But some enrollees were “being automatically enrolled in Plan First,” Malcolm Kletke, a lobbyist representing the Community Mental Health Association of Michigan and other mental health providers, wrote to a Michigan health official, according to emails obtained by KFF Health News through a public records request.
These enrollees had “long received Medicaid due to their disability,” and getting enrolled in the wrong plan meant losing access to “services essential to their recovery and quality of life,” Kletke wrote in September 2024 to Amy Epkey, a senior deputy director of the Michigan Department of Health and Human Services.
In fact, the state’s own records show that Medicaid enrollment for those with disabilities did decline.
Over roughly four years, enrollment in the Medicaid category that includes people with disabilities fell by 10% in the state, according to the Michigan House Fiscal Agency, which provides nonpartisan analysis to lawmakers. The drop was unusual given people generally leave the program because of death or having recovered from a temporary disability, and it’s unlikely those numbers would balloon, said Robert Sheehan, who was the mental health association’s CEO at the time.
Sutfin said the state examined the decline in enrollment and found “several contributing factors, including post‑covid renewal patterns, changes in beneficiary circumstances and movement to other coverage categories.”
After inquiries from KFF Health News, the Michigan health department acknowledged in April that it had made changes to “address concerns raised by advocates.”
Michigan’s computer system now prevents approval of Plan First benefits until all other coverage options are evaluated, Sutfin told KFF Health News. Sutfin said the changes were implemented but “not to correct system errors.”
Sutfin said the state submitted a change request to Deloitte to address this problem. The fix was implemented in January 2025.
Until presented with Kletke’s email, the state had denied there were problems related to Plan First.
Even after the state addressed that issue, other problems persisted.
Noon’s coverage denial notice arrived in September. She fought with the state for months to reverse its decision, “paying cash for all of the medicines through these appeals over and over and over again.”
It was only in January that she was approved.
“I literally cried,” Noon said. “It was a really big deal.”
KFF Health News is a national newsroom that produces in-depth journalism about health issues and is one of the core operating programs at KFF—an independent source of health policy research, polling, and journalism. Learn more about KFF.
This <a target="_blank" href="https://kffhealthnews.org/health-industry/deloitte-medicaid-eligibility-system-denials-michigan-trump-policy-piles-on/">article</a> first appeared on <a target="_blank" href="https://kffhealthnews.org">KFF Health News</a> and is republished here under a <a target="_blank" href="https://creativecommons.org/licenses/by-nc-nd/4.0/">Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License</a>.<img src="https://kffhealthnews.org/wp-content/uploads/sites/8/2023/04/kffhealthnews-icon.png?w=150" style="width:1em;height:1em;margin-left:10px;">
<img id="republication-tracker-tool-source" src="https://kffhealthnews.org/?republication-pixel=true&post=2258559&ga4=G-J74WWTKFM0" style="width:1px;height:1px;">
This article was originally published on KFF Health News.
Author: Penny Jefferson, MSN, RN, CCDS, CCDS-O, CCS, CDIP, CRC, CHDA, CRCR, CPHQ, ACPA-C | July 20, 2026
The Centers for Medicare & Medicaid Services (CMS) is adding another electronic clinical quality measure (eCQM) to the hospital reporting portfolio, but the story doesn’t end there. The 2027 fiscal year (FY) Inpatient Prospective Payment System (IPPS) Proposed Rule signals a broader redesign of hospital quality measurement: fewer traditional process measures, greater emphasis on patient harm and outcomes, a transition from hospital-selected to mandatory reporting, and continued preparation for Fast Healthcare Interoperability Resources (FHIR)-based digital quality measures, or dQMs.
At the time of this writing, these provisions remain proposals, and may change when CMS publishes the final rule. Even so, the direction is becoming increasingly clear. CMS is building an environment in which quality results will be calculated from standardized, interoperable clinical data, rather than assembled primarily through retrospective abstraction.
For the Hospital Inpatient Quality Reporting (IQR) Program, CMS proposes adding three measures. The Excess Days in Acute Care After Hospitalization for Diabetes measure would begin with the FY 2029 payment determination. The Hospital Harm–Postoperative Venous Thromboembolism eCQM and the Advance Care Planning eCQM would begin with the FY 2030 payment determination.
The proposed postoperative venous thromboembolism measure is especially significant, because CMS also proposes removing three process-oriented eCQMs beginning with the FY 2030 payment determination:
These measures generally center on whether an expected process occurred, such as whether appropriate prophylaxis was provided or antithrombotic therapy was prescribed at discharge. The proposed Hospital Harm–Postoperative Venous Thromboembolism eCQM instead focuses on whether a postoperative patient experienced a potentially preventable adverse event.
This does not mean that process reliability is no longer important. Hospitals still must provide appropriate prophylaxis, identify contraindications, and ensure safe discharge treatment. The difference is that quality measurement is moving beyond the question of “Did the hospital complete the expected step?” toward the more consequential question: “Did the patient experience harm, and what does the digital record show about the circumstances?”
CMS also proposes modifying five 30-day mortality measures by including Medicare Advantage (MA) patients and shortening the performance period from three years to two. The affected measures address acute myocardial infarction (MI), heart failure, pneumonia, chronic obstructive pulmonary disease (COPD), and coronary artery bypass graft surgery.
Similar modifications are proposed for the Excess Days in Acute Care measures for acute MI, heart failure, and pneumonia. Combined with the new diabetes measure, these changes broaden the quality lens across payer populations and beyond the initial hospitalization.
CMS is also requesting public comments on the potential use of the Emergency Care Access and Timeliness eCQM in the inpatient setting and the possible future use of the Adult Community-Onset Sepsis Standardized Mortality Ratio measure. These measures have not been proposed for adoption, but their inclusion indicates areas CMS is evaluating for future measurement.
Advance care planning is also part of the proposed eCQM expansion. As discussed in one of my previous articles, advance care planning becomes a quality-data issue when a meaningful clinical conversation occurs, but is not captured in the structured location or format required by the electronic measure. Its inclusion reinforces a broader principle: patient preferences must be both clinically documented and electronically retrievable.
Quality reporting terminology can make implementation dates appear farther away than they are. The payment-determination year is not necessarily the year in which the patient data are collected.
CMS previously finalized the following Hospital IQR reporting schedule:
Therefore, when CMS proposes that an eCQM requirement begin with the FY 2030 payment determination, hospitals should understand that the applicable operational reporting year is CY 2028.
The workflows, structured data capture, measurement logic, testing, validation, and submission processes must be functioning in 2028, not 2030. The payment determination language describes when the reporting requirement affects the Medicare payment update, not when hospitals should begin preparing.
The Hospital IQR Program is a pay-for-reporting program. Hospitals that do not submit the required quality data or otherwise fail to meet all program requirements are subject to a reduction equal to one-fourth of their annual IPPS payment update.
CMS proposes making the Malnutrition Care Score eCQM mandatory beginning with the FY 2030 payment determination, corresponding with the CY 2028 reporting period under the established Hospital IQR schedule.
I have discussed the Malnutrition Care Score in a previous article, including the importance of assessment, diagnosis, intervention, and follow-up. The new development is not the measure’s clinical content, but rather the proposed change in its reporting status.
CMS also proposes establishing a policy under which hospital harm eCQMs would become mandatory after two years of reporting, beginning with the FY 2030 payment determination.
This is the critical shift: a hospital harm eCQM may initially be available as a hospital-selected measure, but it would not remain optional indefinitely. As noted, under the proposed policy, hospital harm eCQMs would become mandatory after two years of reporting. The voluntary period would become an implementation runway toward mandatory reporting.
The hospital harm portfolio includes eCQMs addressing:
The proposed postoperative VTE measure would join this growing portfolio if finalized.
Hospitals that have avoided a technically difficult hospital harm measure by selecting a different eCQM may therefore lose flexibility.
CMS has already finalized a progressive increase in the number of eCQMs hospitals must report: eight total eCQMs for CY 2026/FY 2028, nine for CY 2027/FY 2029, and 11 for CY 2028/FY 2030. By CY 2028, CMS will select eight measures, while only three will remain hospital-selected.
The voluntary years should not be treated as a waiting period. Hospitals need that time to test the measure logic, validate data mapping, investigate discrepancies, correct workflow defects, educate clinicians, and determine whether the electronically calculated result tells the same story as the clinical record.
At the same time, CMS is reshaping the eCQM portfolio and advancing the transition toward dQMs.
CMS defines dQMs as quality measures that use standardized digital data from one or more health information sources, captured and exchanged through interoperable systems. These measures apply standards-based specifications and code packages that can be computed in an integrated environment.
The distinction is more than a change in terminology. Traditional eCQMs have relied heavily on structured electronic health record (EHR) data and the Quality Data Model. The emerging dQM approach uses FHIR-based standards intended to support consistent capture and exchange of quality information across multiple systems.
Potential data sources for dQMs may extend beyond the traditional EHR, and can include:
The Quality Improvement Core, or QI-Core, implementation guide defines FHIR profiles that support interoperable, quality-focused applications for dQMs, including eCQMs. QI-Core is replacing the Quality Data Model as the conceptual framework for constructing digital quality measures, while Clinical Quality Language continues to support computable measure logic.
In early 2026, CMS released draft FHIR-based dQM packages for hospital inpatient, hospital outpatient, and eligible clinician programs for public review. These documents are developmental, may change in response to public input and future rulemaking, and do not establish a final implementation date. Their release, however, demonstrates that the move toward FHIR-based quality measurement has progressed from strategic planning to technical preparation.
For clinical documentation integrity (CDI) and quality teams, the health record must remain clinically understandable to people while becoming increasingly computable by electronic measure logic.
A correct diagnosis documented in a narrative note may not resolve a quality discrepancy when a measure requires a discrete laboratory result, medication administration time, procedure timestamp, structured assessment, or coded exclusion.
Conversely, structured data may trigger a quality event even when the surrounding clinical narrative explains that the condition was present on admission, clinically expected, attributable to another cause, or not representative of preventable harm.
The organizational response cannot simply be “document more.” Hospitals must understand the measure denominator, numerator, exclusions, timing windows, value sets, and risk-adjustment variables. Each required element should then be mapped to its clinical workflow, structured field, and authoritative source system.
CDI can help clarify diagnoses, timing, causation, clinical significance, and present-on-admission status. However, CDI cannot independently repair terminology mapping, interface failures, inaccurate medication timestamps, missing device information, or clinical data stored in a field the measure cannot retrieve.
This work requires collaboration among quality, CDI, health information management (HIM), informatics, analytics, coding, nursing, medical staff leadership, and EHR teams.
Measure validation should compare three elements:
Organizations should not assume that a vendor dashboard represents the final truth without validating how the result was calculated. When a result appears incorrect, the team must determine whether the issue involves clinical documentation, structured-data capture, terminology mapping, measure interpretation, system configuration, or data transmission.
The message for hospitals is clear. The measure portfolio is becoming more outcome-focused. Hospital harm reporting is moving from voluntary selection toward mandatory participation. The technical foundation is shifting from traditional eCQM reporting toward interoperable, FHIR-based dQMs.
FY 2030 may sound distant, but the operational reporting year is CY 2028. Workflow remediation, data governance, measure testing, clinician education, and interoperability preparation all require significant time.
Hospitals should use the optional years to prepare for the required years.
cannot accurately calculate may still affect payment, public reporting, regulatory compliance, and perceptions of care quality.
The transition from voluntary to mandatory reporting should therefore be treated as a call to action. Hospitals should not wait for a measure to become required before determining whether their clinical documentation, workflows, and digital infrastructure are ready to support it.
1. Centers for Medicare & Medicaid Services. FY 2027 Hospital Inpatient Prospective Payment System and Long-Term Care Hospital Prospective Payment System Proposed Rule Fact Sheet. April 10, 2026.
https://www.cms.gov/newsroom/fact-sheets/fy-2027-hospital-inpatient-prospective-payment-system-ipps-long-term-care-hospital-prospective
2. Centers for Medicare & Medicaid Services. FY 2025 Hospital Inpatient Prospective Payment System and Long-Term Care Hospital Prospective Payment System Final Rule Fact Sheet. August 1, 2024.
https://www.cms.gov/newsroom/fact-sheets/fy-2025-hospital-inpatient-prospective-payment-system-ipps-long-term-care-hospital-prospective-0
3. CMS Electronic Clinical Quality Improvement Resource Center. Digital Quality Measure (dQM). Updated June 9, 2026.
https://ecqi.healthit.gov/glossary/digital-quality-measure-dqm
4. CMS Electronic Clinical Quality Improvement Resource Center. QI-Core—Quality Improvement Core: About. Updated March 31, 2026.
https://ecqi.healthit.gov/qi-core/about
5. CMS Measures Management System. Now Open: Public Comment Period for Draft CMS FHIR Digital Quality Measures. February 6, 2026.
https://mmshub.cms.gov/news/2026/2026-02/now-open-public-comment-period-draft-cms-fhirr-digital-quality-measures-dqms
This article was originally published on RACmonitor.
Author: Tiffany Ferguson, LMSW, CMAC, ACM | July 20, 2026
The 2027 Outpatient Prospective Payment System (OPPS) Proposed Rule has listed the intent to remove an additional 637 procedures from the Inpatient-Only (IPO) List as the second phase of its three-year elimination strategy. The Centers for Medicare & Medicaid Services (CMS) stated several times in the ruling that they are leaving only the most clinically complex services for removal in 2028.
If finalized, nearly half of the remaining IPO List procedures will become eligible for either inpatient or outpatient payment, based on medical necessity, rather than a predetermined designation. The proposal includes procedures across multiple clinical families, including digestive, respiratory, urinary, endocrine, maternity, male and female genital, mediastinum and diaphragm, hemic and lymphatic systems, and auditory services. CMS intentionally delayed removal of neurological procedures, cardiovascular procedures, and transplant-related services until 2028, acknowledging their greater clinical complexity and the need for additional evaluation of appropriate Ambulatory Payment Classification (APC) assignments.
CMS explained that the procedures proposed for removal generally require fewer modifications to the existing APC structure than the more complex procedures planned for 2028. According to CMS, many of the services proposed for removal already have clinical characteristics and resource utilization similar to procedures currently paid under the OPPS. In contrast, CMS noted that neurological, cardiovascular, transplant, and other highly specialized procedures will require additional review because of their greater clinical complexity, and may necessitate revisions to existing APC or Comprehensive APC (C-APC) payment methodologies before they can appropriately transition to outpatient payment.
CMS reiterated in the ruling its policy that once a procedure is removed from the IPO List, it becomes eligible for payment in either the inpatient or hospital outpatient setting. The appropriate setting continues to depend on whether the service is reasonable and necessary, based on the individual patient’s clinical circumstances and existing Medicare coverage policies. Thus, while the procedure itself may no longer auto classify as an inpatient admission, physicians must continue to determine the appropriate level of care based on the patient’s overall condition, expected hospital stay, comorbidities, procedural risk, and anticipated postoperative care needs.
For decades, the IPO List served as a safety net. Certain procedures were automatically considered inpatient, eliminating much of the clinical debate surrounding admission status. As this list disappears, hospitals are losing a regulatory shortcut, and must instead rely on physician documentation and strong utilization management processes to support level-of-care decisions.
This article was originally published on RACmonitor.
Author: Christine Geiger, MA, RHIA, CCS, CRC | July 20, 2026
July is coming to an end, so that means there are hopefully only a few days until we get the Inpatient Prospective Payment System (IPPS) Final Rule. That’s also just enough time to take a look at a couple of the proposed Diagnosis-Related Group (DRG) changes.
The first one is in MDC 05, Diseases and Disorders of the Circulatory System, and deals with cardiac pacemaker revisions and replacements. The proposal is to delete the five MS-DRGs related to these procedures: MS-DRGs 258, 259, 260, 261, and 262. DRGs 258 and 259 relate to cardiac pacemaker replacements with or without a major complication or comorbidity (MCC). DRGs 260-262 relate to cardiac pacemaker revisions with a three-way severity split. If something is deleted, there has to be a replacement for these cases. Two new proposed combined MS-DRGs will take their place with a two-way severity split, MS-DRGs 210 and 211.
MS-DRG 210 will be Cardiac Pacemaker Revision or Device Replacement with MCC, and MS-DRG 211 will be Cardiac Pacemaker Revision or Device Replacements without MCC. It has been 43 years since DRGs for pacemaker revision and replacement procedures were created. The proposed rule notes that this change was based on their analysis of claims data from the 2025 fiscal year (FY). It shows that the resource utilization now appears to be aligned, and the cases are now clinically coherent, making the restructuring of these DRGs appropriate. As part of this restructuring, PCS code XHH80HB, Insertion of Ultrasound Transmitter and Battery for Endocardiac Pacing Electrode in Chest, Subcutaneous Tissue and Fascia, Open Approach, New Technology Group 11, will assign to new DRGs 210 and 211 when reported as a standalone procedure.
We will stay in MDC 05 for our next DRG change. There is a proposal to delete MS-DRG 264, Other Circulatory System OR Procedures. Again, we know that if something is deleted, there has to be a replacement. Two new MS-DRGs are proposed here, MS-DRGs 361 and 362. MS-DRG 361 will be Other Circulatory System OR Procedures with MCC, and MS-DRG 362 will be Other Circulatory System OR Procedures without MCC. In this case, a review of claims data supported the restructuring of the MS-DRGs with a two-way severity split, noting either with or without MCC. All the 1,447 procedure codes currently in the GROUPER logic for MS-DRG 264, which is proposed to be deleted, will be reassigned to the GROUPER logic for new MS-DRGs 361 and 362.
Finally, we look at some changes regarding prostatectomy procedures. These changes will affect both MDC 11, Diseases and Disorders of the Kidney and Urinary Tract, and MDC 12, Diseases and Disorders of the Male Reproductive System. In MDC 11, eight PCS code combinations will be removed from the GROUPER logic for MS-DRGs 665-667. These are Prostatectomy with MCC, with CC and without CC/MCC. In MDC 12, the same eight PCS code combinations will be removed from the GROUPER logic for MS-DRGs 707 and 708, Major Male Pelvic Procedures with and without CC/MCC, respectively. PCS codes 0VT00ZZ, Resection of prostate, open approach and 0VT04ZZ, Resection of prostate, percutaneous endoscopic approach, are proposed to group to MS-DRGs 707 and 708. PCS codes for resection of prostate via a natural or artificial opening, 0VT07ZZ and 0VT08ZZ for endoscopic, would group to MS-DRGs 713 and 714.
This is just a sampling of the MS-DRG changes in the IPPS proposed rule. We don’t have long to wait to see which of the proposed changes will be included in the final rule.
Make sure you and your coding team are prepared for the upcoming changes.
This article was originally published on RACmonitor.
July 17, 2026
Industry giant UnitedHealthcare is adding its voice to the chorus of insurers criticizing the current state of the No Surprises Act’s independent dispute resolution process.
This article was originally published on Fierce Healthcare.