Digital Quality Measurement Now Has Dates: What the MSSP 2027 Proposed Rule Means for ACOs

Digital quality measurement now has dates attached. In the Calendar Year 2027 Physician Fee Schedule proposed rule, the Centers for Medicare & Medicaid Services (CMS) set out for the first time how Medicare Shared Savings Program accountable care organizations (ACOs) would move to quality reporting computed from clinical data exchanged through the HL7® FHIR® standard, floating optional reporting as early as CY2028 and required reporting for applicable measures by CY2030.

The financial provisions in that rule drew most of the attention, and reasonably so. Sharing rates, benchmark adjustments, and the guardrail on the Accountable Care Prospective Trend all move real money. The quality reporting half got less notice, and it will shape how ACOs operate for the rest of the decade.

Here is what this piece covers:

• What CMS firmly proposed, and what it only asked about
• Why digital quality measurement is a computation capability rather than a new submission format
• What ACOs stand to gain from the transition, beyond compliance
• What leaders should be working through now, and how to weigh in before comments close on Monday, September 14, 2026

What CMS proposed, and what it only asked about

The distinction between a firm proposal and an open question matters here more than usual.

Three changes in the rule are firm proposals, and each one lowers the near-term burden on ACOs rather than raising it. CMS proposes to keep the Merit-based Incentive Payment System clinical quality measure (MIPS CQM) collection type available for performance year 2027 and beyond instead of sunsetting it, which spares ACOs a disruptive switch in the middle of a larger transition. It proposes a new Medicare electronic clinical quality measure (eCQM) collection type, letting ACOs report electronic measures on their assigned beneficiaries rather than an all-payer, all-patient population. And it proposes that an ACO can satisfy the certified technology requirement through one of three paths, including attesting that data collected through and HL7 FHIR-based API and a certified health IT module supported complete reporting of at least one of the five ACO-reported APP Plus measures.

Read together, those are the actions of an agency clearing a path. CMS is explicit that continuity in the near term lets ACOs put their resources toward the digital transition instead of toward interim busywork.

The timeline itself is a different kind of document. The dates that have drawn attention, optional digital reporting beginning in CY2028 and required reporting for applicable measures by CY2030, appear in a Request for Information (RFI) rather than in a proposal. That distinction cuts both ways. RFI dates are not binding and can move. They are also the clearest statement CMS has made about where this is going, and the direction has been consistent for years.

Treat the RFI for what it is: the clearest signal CMS has given about direction, with nothing binding behind it

For a board or an executive team, the practical reading is straightforward: plan against the direction, hold the specific dates loosely, and use the comment period to influence what the eventual requirement looks like.

Why digital quality measurement is a different kind of change

Digital quality measurement is often described as a new way to submit the same information. That framing undersells what is involved and leads organizations to budget for it as a reporting project.

Most quality reporting today is a data-entry operation. Charts are abstracted, values are entered, files are submitted, and the cycle repeats for every measure, every payer, every year. Digital quality measures are computed directly from FHIR resources against certified measure logic. The work moves from manual effort to building a clinical pipeline that runs continuously. Those are different disciplines with different staffing, different testing requirements, and a different failure mode. Being connected to the data is not the same as producing an accurate, submittable result, and the distance between those two states is where most of the effort lives.

Here is the case for starting early. The gap between connected and correct takes time to close, and closing it while your existing reporting still works as a fallback costs a fraction of what it costs under deadline pressure.

What ACOs stand to gain from digital quality measurement

The compliance framing obscures the more interesting part. The capability CMS is steering ACOs toward is one that a well-run accountable care organization would want regardless of what the final rule says.

• Measures computed from live clinical data can surface care gaps during the performance year, while there is still time to close them, instead of confirming after reconciliation what was missed.
• The same FHIR architecture built for Medicare quality reporting can serve commercial and Medicare Advantage value-based contracts, so the investment is spread across the whole book of business.
• Clinical data drawn from electronic health records, registries, and health information exchanges gives a fuller picture of care that was actually delivered than claims alone can provide.
• Retiring parallel manual reporting removes a recurring labor cost that scales with every additional measure, payer, and cycle.

This is the same argument the financial provisions make from the other direction. More predictable benchmarks reward organizations that can see their performance early enough to act on it. Digital quality measurement is one of the capabilities that makes seeing early possible.

What ACO leaders should be working through now

Nothing on this list requires a large commitment this year. All of it takes longer than executives expect.

• Where your clinical data lives today, what format it is in, and how much of it is already FHIR accessible
• Whether your quality reporting partners have a working computation pipeline that meets certified module requirements, and when they expect it to be ready.
• What your rates look like when measured digitally against how they are measured today, which is the kind of thing better learned in a test environment than in a submission
• How a digital measurement capability would serve your commercial and Medicare Advantage contracts alongside your Medicare Shared Savings Program reporting
• Whether your organization intends to comment on the rule before September 14, 2026, and what you would want the eventual timeline to look like

There is no prize for being first, but there is a cost to being rushed.

The organizations that struggle with transitions like this one are rarely the ones that started late. They are the ones that started without a plan, or that treated a multi-year change as a procurement decision to be made in the final year. Pacing matters more than speed.

Where we sit on this

I spent part of my career inside the National Committee for Quality Assurance (NCQA), where I served as Assistant Director of Measure Validation and managed the Certified HEDIS® Compliance Audit program, followed by more than 14 years running payer quality solutions. That experience shapes how I read a rule like this one. Measure specifications reflect judgment calls about what can be computed reliably and what cannot. The organizations that navigate a measurement transition well are the ones that understand those calls, rather than only the deadlines attached to them.

Inovalon® has worked in quality measurement and Medicare risk adjustment for more than 25 years. Inovalon’s Converged Quality engine has earned NCQA HEDIS certification for 26 consecutive years and NCQA validation for its digital quality measure engine, and our view of this transition is consistent with how we have approached every measurement change before it. Move deliberately. Test before you need to depend on it. Keep what works running while you build what comes next. We believe the next phase of accountable care will reward organizations that build measurement into care delivery, where it can change a decision while the performance year is still open.

CMS has given accountable care leaders something they did not have before on digital quality: a direction with dates attached, and an open comment period in which to weigh in on it. That is a better position than the ambiguity that came before it.

Talk to a value-based care specialist about performance visibility across your value-based contracts.

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