Through its Calendar Year 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P), the Centers for Medicare and Medicaid Services continues to drive a transition to a digital, interoperable, and value-based care healthcare ecosystem.

HIMSS has identified six critical areas of the proposed rule that will impact HIMSS members.

CMS released the proposed rule July 14, detailing several potential policy changes impacting providers, patients, and developers of healthcare technology.

The proposals are intended to better leverage information and technology to improve patient outcomes, optimize clinician workflows, and establish safe pathways for artificial intelligence in clinical practice.

1. Transition to Mandatory Reporting of MIPS Value Pathways (MVPs) in 2029

In one of the most significant changes to the Quality Payment Program since its inception, CMS has proposed to sunset traditional Merit-based Incentive Payment System (MIPS) reporting beginning with the 2029 performance year. In its place, the agency is accelerating the transition to MIPS Value Pathways. Under the CY 2027 proposal, CMS plans to aggressively expand and transition clinicians to these specialized, specialty-specific pathways.

2. Mandatory Reporting of Core Measures

To drive national clinical alignment and standardize quality benchmarking, the CY 2027 rule proposes the mandatory reporting of a formalized set of "Core Measures" across various payment tracks. Under this proposal, providers will no longer have the luxury of choosing disparate, low-impact quality metrics. Instead, they must report on uniform, high-priority measures targeting chronic disease, preventative health, and care equity.

3. Deepening the Commitment to Digital Quality Measures (dQMs)

The transition from manual, retrospective chart abstraction to real-time, electronic reporting takes a leap forward under the CY 2027 proposed rule. CMS has outlined a timeline and technical specifications to transition MIPS and Accountable Care Organization quality metrics entirely to digital quality measures. By leveraging FHIR® (Fast Healthcare Interoperability Resources) data standards, dQMs are intended to allow health systems to extract quality data directly from certified EHR technology without manual clinician intervention.

4. Proposed Upgrades to Promoting Interoperability Requirements

The Promoting Interoperability performance category undergoes revisions under the CY 2027 proposal. CMS is raising the bar on data exchange by proposing to tighten requirements around multi-factor authentication, clinical data exchange with public health registries, and patient portal access. Most notably, the proposed rule mandates the adoption of upgraded, certified health IT standards to ensure seamless bi-directional data flow. These changes align with changes proposed by the Office of the National Coordinator the HTI-5 proposed rule.

5. Evolving Remote Patient Monitoring (RPM) Frameworks

CMS is proposing to refine and expand reimbursement structures for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring. The CY 2027 rule proposes updated billing codes, clearer guidelines on the clinical staff time required to manage device data, and revised criteria for "established patient" relationships to ensure that RPM technologies can be safely initiated in a broader array of clinical scenarios. Most notably, CMS proposed to no longer pay for third parties to run remote patient monitoring programs.

6. Request for Information (RFI) on Technology and AI Payments

CMS has issued a Request for Information (RFI) regarding payment models for the use of advanced technology and artificial intelligence in clinical workflows. The RFI seeks public input on how Medicare should value and structure payments for autonomous AI diagnostics, clinical decision support tools, and generative AI scribes.

Public Comment and Next Steps

HIMSS is actively convening its member workgroups spanning clinical informatics, policy, digital health transformation, quality, and cybersecurity to draft comprehensive public comments on these proposals. The 60-day public comment window for the CY 2027 Physician Fee Schedule proposed rule closes on Sept. 14, 2026.

HIMSS encourages all healthcare information and technology stakeholders to participate in this vital feedback process to ensure the final rule supports a highly usable, secure, and innovative digital health environment. Email policy@himss.org to learn more.