CMS’ Roadmap for Switching to FHIR-Based Digital Quality Measures

The Centers for Medicare & Medicaid Services (CMS) is moving steadily toward the use of FHIR-based digital quality measures (dQMs). CMS believes dQMs will enable a more dynamic, interoperable, and comprehensive approach to quality measurement than the electronic clinical quality measures (eCQMs) currently in use. 

As it seeks public feedback on draft dQM packages, CMS officials held a webinar in January to explain the expected transition. 

One of the webinar speakers was Joel Andress, the digital quality measurement lead at CMS, who heads up efforts to develop and implement a strategy to convert CMS quality measurement to a digital format. The goals are to reduce reporting burden for care providers and promote data interoperability. 

"We're hoping to set expectations for upcoming changes in how quality measures are developed, implemented, and reported across our programs and give you an opportunity to actively participate in that transition,” Andress said. 

He noted that digital quality measures enable alignment between clinical care, reporting requirements, and program accountability that have long been sought in CMS quality programs.

“Our belief is that by implementing digital quality measures, we'll be able to support the long-term sustainability of these programs and greater improvement in the quality of care in our provider systems,” Andress said. 

He explained what it means that CMS programs are transitioning from traditional measures to FHIR-based digital quality measures. These changes may include updated measure logic, new data requirements, and enhanced technical specifications, and are designed to improve measure validity, increase the interoperability of the data being collected, and support automated reporting within CMS’ programs, he explained. 

“We are seeking to ensure that there is an alignment between human-readable and computable specifications that we've developed in the FHIR standard, ensure that there's a feasibility of collecting required data elements in EHR systems, and try to get a sense of what the potential impact on reporting workflows and provider burden would be given the changes to these measures,” he said. 

The feedback period will give CMS an opportunity to obtain clear insight into the transition of digital quality measurement, equip stakeholders with the context needed to understand what CMS is changing about these measures and the presentation of information regarding them, and to enable meaningful participation in the development and implementation process. 

These measures converted to FHIR will ultimately represent a subset of digital quality measures that will be a much more expansive category and incorporate other sources of data and reporting. While related, Andress explained, digital quality measures are distinct from the current program eCQMs and are built on a different data model and technical foundation.

The eCQMs have been used for many years across CMS Quality Reporting Programs. They're based on the Quality Data Model, or QDM, which is designed specifically for CMS use and primarily for reporting from electronic health records.

The eCQMs have enabled automated reporting compared to manual abstraction, but are limited in their interoperability and are closely tied to EHR-based data sources. Digital quality measures, on the other hand, are built on FHIR standard and use interoperable data, Andress said. They use that as an interoperable data model. Designed to be modular, reusable, and scalable across programs and use cases, the measures can include data requirements that are not confined to a single system.

Digital quality measures expand the concept of data sources to include medical devices, clinical systems, patient-facing applications, and other digital health technologies beyond traditional EHRs.

Converting eCQMs to dQMs 

Andress explained that “converting eCQMs to dQMs preserves existing measure intent while modernizing the technical foundation, and that positions CMS quality programs for greater interoperability, reduced reporting burden, and more comprehensive and timely quality insights.”

FHIR, he added, provides a comprehensive framework for implementing clinical quality measures and offers a standardized set of resources and operations that support the representation, sharing, and evaluation of clinical knowledge artifacts. “Additionally, it's not constrained simply to the quality measurement purpose, and this means that the data are interoperable for a variety of purposes, not simply within our reporting programs,” Andress said. “The framework enables standardization and interoperability by using consistent data formats and structures and facilitating seamless integration across the diverse healthcare systems.”

FHIR’s modular design and RESTful APIs support rapid implementation, scalability, and adaptability to the evolving requirements. Data collected for the purpose of CMS’ program are reusable for different purposes, increasing the efficiency of the data collection, he said. FHIR also supports efficient handling of large data sets and enables population-level analysis and reporting.

Currently, there are 157 resources in FHIR, and Andress shared some common resources in use with CMS digital quality measures included in this public comment period. 

The clinical module includes allergy intolerance, condition problems, procedure, and care plans resources. Some resources may reference other resources, such as service requests. The diagnostics module includes observation and diagnostic report.

Andress explained that the QI-Core Implementation Guide (IG) is a FHIR-based implementation guide developed to standardize how clinical data are represented for quality measurement and improvement. It provides a bridge between clinical care data and digital quality measures. This IG ensures consistent and interoperable representation of clinical concepts needed for quality measurement, facilitates the transition from traditional eCQMs based on the QDM to FHIR-based digital quality measures, and supports quality reporting programs, clinical decision support, and population health initiatives.

“In a nutshell, the QI-Core IG is a foundational guide that defines how clinical data should be represented in FHIR so that quality measures can be accurate, interoperable, and implementable,” he said. 

Other IGs that are key to the implementation of measures include the Quality Measure IG, or QM IG, which essentially defines how a measure is constructed, and the DEQM, or Data Exchange for Quality Measures IG, which defines how to exchange digital quality measurement data between systems, i.e., how to report the measures to CMS when it's time to do so.

Andress described a tool called MADiE (Measure Authoring Development Integrated Environment) that is designed for the creation, testing, and management of both eCQMs and digital quality measures.

“MADiE streamlines the development, testing, and management of quality measures to improve healthcare reporting outcomes. MADiE's role is also to publish the artifacts that are there for you to assist you in the implementation of these measures,” he said. “So much of what you'll be reviewing in the public comment beginning today comes from the MADiE system.”

With the dQM public comment period, CMS is publishing the dQM measure packages for those measures CMS has converted to the FHIR standard, he said. “The publication of these packages containing these files that I've described includes what we believe to be an appropriate representation of the artifacts that would publish in future annual updates for those dQMs. So essentially we’re presenting to you what we think measure packages would look like once we implemented FHIR digital quality measurement reporting.”

Andress concluded by sayiing that stakeholders now have a way to see how CMS has mapped out these measures, what they look like, and provide feedback. “We also want to hear about any ambiguities in how we've presented the materials, whether or not something's missing that would be important to include, or if something is presented in a way that’s difficult to use.” 

The draft dQM packages are available through ONC JIRA tickets, including 17 hospital inpatient digital quality measures, four hospital outpatient digital quality measures, and 49 eligible clinician digital quality measures. Test case exports are provided for some of those measures, and public comments are open through Feb. 23, 2026.