Use Case: CMS Measures


Run your CMS quality measures on FHIR data with an open CQL engine. See where you stand while the performance period is still open, not after the submission deadline has passed.

What you can do with Firely

Execute eCQM logic expressed in CQL against your FHIR data. No re-implementation of published specifications into a proprietary rules engine, and no waiting on a vendor release to see what a specification change does to your rate.

The same CQL layer serves Hospital IQR and Promoting Interoperability, MIPS and MVPs, your ACO’s APP Plus set, and the payer contracts built on the same clinical concepts. Implement once instead of once per program.

Measures run against live FHIR data, so gaps surface while the performance period is still open and there is still something you can do about them.

Standardized CQL artefacts and FHIR MeasureReports let you follow a rate back to the patients and data elements behind it. For your own quality team, your auditor, and the clinicians you are asking to change something.

Your measure logic is locked inside your reporting stack

Most provider organizations do not own their measure logic. It lives inside a certified EHR module or a registry vendor’s platform, expressed in a form you cannot read, on a release cycle you do not control.

That is workable when you report once a year and accept the number that comes out. It stops being workable the moment you want to know where you stand in month four, model what a specification change does to a rate, or run the same measure for a payer contract your reporting vendor does not cover.

And the programs keep stacking. A single health system typically reports into all of these at once:

  • Hospital Inpatient Quality Reporting (IQR) — for the hospital
  • Merit-based Incentive Payment System (MIPS), or a MIPS Value Pathway (MVP) — for its clinicians
  • APM Performance Pathway Plus (APP Plus) — for its accountable care organization
  • Contractual quality measures — for two or three payers

Same clinical concepts, separate implementations, different answers.

Where CMS is heading, and what is actually settled

CMS is moving toward FHIR-based quality measurement. Every program you report into is on that path, Hospital IQR, MIPS, MVPs and APP Plus alike. How far each one has actually traveled is another matter.

Today In effect
QRDA is the submission format

Hospital IQR and Promoting Interoperability take QRDA Category I; MIPS takes Category III. No CMS program accepts FHIR-based measure submission in production.

Now In testing
FHIR measures exist, and are published

Since February 2026, three draft FHIR measure packages are out for comment, built on QI-Core. CMS reports FHIR specifications for more than 70 measures. None of it is reportable until finalized through rulemaking.

PY2028–PY2030 Signalled (RFI)
Dates exist, for one program

The CY2027 Physician Fee Schedule raises optional digital reporting for Shared Savings Program ACOs from PY2028 and mandatory FHIR from PY2030 — in a Request for Information, which is a consultation rather than a proposal.

The submission format is not changing this year, CMS has set no industry-wide deadline, and the one set of dates that exists sits in a consultation about one program. What has not been contradicted in any CMS document since 2022 is the direction.

Your FHIR data is arriving regardless

You are not being asked to bet on FHIR. You are already getting it.

ONC / ASTP CERTIFICATION

Your certified EHR is required to expose a standardized FHIR
API.

CMS Interoperability & Prior Authorization

Your payers must stand up FHIR APIs for patient access, provider access and prior authorization by January 2027.

USCDI defines the data elements. TEFCA defines the exchange. None of it depends on digital quality measurement going anywhere at all.

So the question is not whether FHIR will happen. It is whether you do anything with the FHIR data you are going to have. If CMS slows down on digital quality measures, that data does not disappear. A measure layer built on it sits on infrastructure that exists for other reasons, and stays useful whatever CMS decides next.

Where measure performance turns into payment

Quality reporting is not one obligation with one consequence. Depending on which programs you are in, the same clinical logic feeds three different payment mechanics.

A penalty

Hospital IQR & Promoting Interoperability

Hospitals that do not meet Inpatient Quality Reporting requirements lose a quarter of their annual payment update. The eCQM set is fixed and shared between the two programs: eight measures, all four quarters, one deadline.

At stake

A quarter of the annual payment update

A sliding scale

MIPS and MVPs

The 2026 performance threshold is 75 points, and adjustments are applied two years after the performance year. Quality is the largest scored category for most clinicians.

At stake

Up to ±9% of Medicare Part B payment

A gate

Shared Savings Program ACOs

Quality performance gates shared savings. Miss the standard and the savings you generated are not paid out.

At stake

The shared savings you earned

For ACOs, CMS has also added an eCQM collection type that allows reporting on assigned beneficiaries rather than the full all-payer population, a materially lower data bar for electronic reporting.

Same measures. Different moment.

Nothing about the measures changes. What changes is the point at which you see the result, and whether there is still anything you can do with it.

How most organizations measure today

After the performance period closes

You learn what your score will be.

By the time the number exists, the period is closed.

With measures running on live FHIR data

Throughout the performance period

You learn what you can still change.

A gap found in month four is still a gap you can close.

How it works

Your FHIR data stays where it is. Firely Server runs inside your environment, against your existing pipelines and governance. No rip-and-replace, and no second copy of your clinical data.

Measure logic, as published CQL artefacts

FHIR Measure + Library containing CQL — the form CMS publishes its draft FHIR measures in

Input Your FHIR data

Clinical · claims · registry feeds, in your existing pipelines

Execution Firely Server

Production CQL engine
$evaluate-measure

Output FHIR MeasureReport

Patient level and population level, for your analytics, dashboards or care management

Unchanged

Your existing certified submission path. You keep reporting to CMS the way you do today, through your certified system, in QRDA Category I or III. Firely runs alongside it.

Want the technical detail? Read about CQL on FHIR →

Questions we get asked

Does this replace our certified EHR reporting?

No. Certification for capturing, calculating and reporting CQMs sits with your Health IT Module under the ONC/ASTP Health IT Certification Program, and submission to CMS still goes through QRDA. Firely is the measure execution layer next to it: the place where you can run the logic yourself, on your own schedule, against your own FHIR data.

Is there a CMS certification for CQL engines?

No. CMS does not certify measure calculation engines. The certification that applies in CMS programs is ONC/ASTP health IT certification under the CQM criteria at §170.315(c)(1)–(c)(4), and it attaches to the Health IT Module you report through — not to a calculation engine. This is a real difference from the HEDIS world, where NCQA certifies engines directly.

What if CMS never finalizes FHIR-based reporting?

Then you keep submitting QRDA exactly as you do now — Firely was never the submission path. What you would still have is visibility into where you stand during the performance period, one logic layer instead of one per program, and measure logic you can read and change yourself. None of that depends on a rulemaking.

Can we use this before CMS accepts FHIR submissions?

That is the normal case today, and it is where most of the value sits. Running measures on live FHIR data during the performance period gives you visibility you do not have now, whatever format you submit in at the end of it.

Does CQL hold up at scale?

Firely Server is a production FHIR server with a built-in CQL engine, deployed on-premises and in cloud. Performance at scale is where we focus.

We report HEDIS measures too. Is that a separate implementation?

No. Same engine, same CQL layer, different measure artefacts. Plans, and the vendors reporting on their behalf, run HEDIS® and CMS measures through one deployment.

Why Firely

  • We maintain the CQL engine this runs on. The open-source .NET CQL SDK is ours. It has been tested against current CMS and NCQA measure content, and when the logic does something unexpected, you can read the code and so can we.
  • We helped build the standard this runs on. Firely's team contributes to HL7 FHIR and its implementation guides. You are working with the specification, not with one vendor’s reading of it.
  • The industry builds on our tooling. The Firely .NET SDK has passed 5 million downloads, across 13 years of FHIR work and more than 32,000 commits.
  • We teach this work. Our course Implementing CQL based Quality Measures covers measure logic, data requirements, testing and reporting. Because CQL is approachable and operationalizing it across measure sets, data quality and governance is where teams actually get stuck.
  • Nothing is a black box. Open CQL artefacts in, FHIR MeasureReports out, and a documented path from a number back to the patients behind it.