September 14, 2026
Dr. Mehmet Oz, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Ave. SW
Washington, DC 20201
Attention: CMS-1848-P
Dear Dr. Oz:
About NCQA and Our Perspective on This Rule
The National Committee for Quality Assurance (NCQA) appreciates the opportunity to comment on the CY 2027 Physician Fee Schedule (PFS) proposed rule. NCQA is a private, 501(c)(3) not-for-profit, independent organization dedicated to improving health care quality through our accreditation, recognition, and measurement programs. NCQA-stewarded HEDIS measures inform quality in plans covering more than 200 million lives, and more than 10,000 practices hold NCQA Patient-Centered Medical Home (PCMH) Recognition, giving us direct, real-world insight into these proposals.
NCQA strongly supports the direction of this rule. CMS is moving Medicare toward outcomes that matter, meaningful and more harmonized measures, greater value from public programs, and more person-centered, prevention-oriented care. These priorities echo what we heard through dozens of listening conversations and multi-stakeholder convenings on Medicare and Medicaid quality over the past year engaging CMS, states, plans, provider organizations, and measurement experts. The consensus was consistent: measure what matters, simplify, harmonize, advance digital and AI, and act as a trusted steward, with actionability as the unifying test. We also support CMS’s effort to strengthen Original Medicare as a robust, affordable choice for beneficiaries by expanding accountable care, improving access, and ensuring public resources produce greater value.
Our central message is this: Medicare cannot achieve better outcomes by modernizing payment, measures, and data in separate lanes. It should invest adequately in comprehensive, team-based care, assign accountability to the actors with the ability to improve, rely on impactful outcome signals, and ensure the data underlying those signals are timely, interoperable, and trustworthy. This rule makes real progress on each, and our recommendations aim to connect them so that investment, accountability, measurement, and data reinforce one another to improve outcomes for every beneficiary, including those in rural and safety-net settings.
Summary of Recommendations
NCQA offers the following recommendations for the CY 2027 Physician Fee Schedule; Medicare Shared Savings Program; and Quality Payment Program Proposed Rule:
Redesigning Primary Care RFI
- Advance prospective, population-based primary care payment, including hybrid and capitated approaches, as the foundation for comprehensive, team-based primary care paired with accountability for capabilities and outcomes.
- Let practices demonstrate capability and readiness through nationally recognized, independently governed, evidence-based frameworks; NCQA’s PCMH Recognition and Primary Care Advancement program illustrate the approach.
- Continue integrating behavioral health, shared medical visits, health coaches, and lifestyle-oriented prevention into primary care payment and accountability.
- Explore a use-case-specific learning collaborative that could help CMS and the field generate evidence, define outcomes and risks, and inform appropriate safeguards, payment policies, and accountability expectations as AI applications evolve.
Medicare Shared Savings Program
- Support the growth and accessibility of accountable care and connect that expansion to beneficiary outcomes, access, continuity, and value, while welcoming the rule’s burden-reduction improvements.
- Demonstrate whether a sufficient accountability signal remains before removing the Substance Use Disorder Treatment and Adult Immunization measures from APP Plus; if no sufficient signal remains, retain them or identify a stronger replacement and transition pathway.
- Align incentives and scoring so that early adopters of Medicare eCQMs and FHIR-based reporting are not disadvantaged relative to legacy pathways.
Quality Payment Program and MVP Transition
- Create a parsimonious core of outcome-aligned measures; build MVPs and Core Measures on nationally recognized digital quality measures.
- Retain cross-cutting accountability for prevention, behavioral health, chronic disease, experience, and function as MIPS sunsets, using patient-reported outcomes to test whether patients improve.
- Connect MVP measures to other Medicare accountability so the same clinical concept is not specified differently across ACO, hospital, health-plan, and clinician programs.
FHIR-Based Digital Quality Measurement RFI
- Stage and support the transition to digital measures, with clear standards, guidance, workflow support, and parallel testing as part of FHIR-based reporting.
- Treat data quality as foundational by assessing whether source data are complete, conformant, timely, traceable, and fit for measurement and accountability.
- Engineer the transition so all ACOs can move toward digital quality measurement with appropriately aligned incentives without relying on legacy reporting pathways.
Specialty Care and Clinical Coding RFIs
- Align MVPs, specialty accountability, and ACO measurement around shared outcomes and measures.
- Adopt the restructured CPT maternity codes rather than new HCPCS G-codes and prioritize stability and transition time in any coding modernization.
Redesigning Primary Care to Make America Healthy Again RFI
Fund comprehensive, team-based primary care
NCQA commends CMS for using this RFI to confront a structural problem that was raised in our Medicare and Medicaid convenings this year: primary care is chronically underinvested in, even as it carries growing responsibility for prevention, chronic disease management, behavioral health, and whole-person care. Accountability without aligned investment does not change outcomes; it accelerates burnout. The evidence supports moving decisively toward prospective, population-based payment. A strong body of research associates accessible, continuous, and comprehensive primary care with better outcomes, fewer avoidable hospital and emergency department visits, and lower total cost of care; research examining PCMH-recognized practices has similarly found reductions in total expenditures and emergency department utilization.1 2 Where value-based arrangements provide real population accountability and aligned economics, primary care teams become better equipped to adjust workflows and intervene earlier. Hybrid models layered on fee-for-service ask primary care to deliver population health without the means to achieve it.
NCQA therefore encourages CMS to advance prospective primary care payment, including hybrid and capitated approaches along the risk continuum. New approaches should be paired with clear expectations for care-delivery capabilities and accountability for outcomes, so flexibility produces measurable improvement rather than a new billing construct.
To support that accountability, CMS should allow nationally recognized, independently governed, evidence-based frameworks to demonstrate primary care capability and readiness. Acceptable frameworks should address core functions such as access, continuity, comprehensiveness, coordination, behavioral health integration, population management, interoperable data use, and continuous improvement. NCQA’s longstanding PCMH Recognition and our Primary Care Advancement program, launching this November and aligned with the APCM codes, illustrate how such frameworks can operationalize these expectations and create an evidence-based pathway that meets practices where they are, while encouraging advancement toward value.
Advance whole-person care through behavioral health and person-centered services
NCQA applauds the proposals that strengthen whole-person primary care, including integrated behavioral health through the Collaborative Care Model, national pricing for health coaches, and new shared medical appointments and group visits. The need is acute: primary care is a critical front door for behavioral health, yet screening and diagnosis do not consistently translate into timely, sustained, evidence-based treatment, leaving a substantial gap between identifying need and improving outcomes.3 NCQA’s experience with Behavioral Health Distinction in PCMH Recognition demonstrates that behavioral health is most effective when embedded into routine primary care capabilities, team-based workflows and continuous improvement, rather than treated as a standalone add-on. To build on that foundation, NCQA is developing and field-testing a core set of behavioral health measures with diverse implementation partners through the NCQA-West Health Advancing Behavioral Health initiative. We encourage CMS to continue embedding behavioral health, lifestyle medicine, and team-based prevention into future primary care payment and accountability, and to explore reducing cost-sharing barriers for high-value primary care, behavioral health, and preventive services.
Enhance primary care through responsible AI
NCQA commends CMS’s interest in AI-enabled care models and offers a concrete learning and evidence-generation model now being implemented in a high-risk use case. AI adoption is accelerating; however, the field needs safeguards alongside structured learning that can inform durable, evidence-based standards. Building on a 2025 convening of more than 30 health plans, systems, and AI vendors, we launched the NCQA AI Learning Collaborative. The Collaborative is a cohort-based program focused on real-world implementation, outcomes, and evidence and organized around four themes: 1) impact on access, 2) variation across vulnerable groups, 3) transparency and human oversight, and 4) outcomes after denial or appeal. We would welcome exploring whether a similar use-case-specific learning collaborative could help CMS, primary care organizations, technology developers, patients, and clinicians define meaningful outcomes, risks, and evidence needs before AI payment or accountability expectations are formalized.
As AI matures, CMS should distinguish tools that reduce administrative work, tools that influence clinical decisions, tools that generate measurement data, and tools that deliver aspects of clinical care historically requiring a licensed clinician, each warranting a different level of scrutiny. Before Medicare payment policy rewards AI-enabled primary care, CMS should establish what evidence demonstrates that a use case improves access, clinician capacity, safety, coordination, patient experience, or health outcomes, and what ongoing monitoring is needed to sustain those results.
Medicare Shared Savings Program
Strengthen accountable care, and connect its expansion to outcomes
NCQA supports CMS’s effort to make accountable care more accessible, sustainable, and attractive across Original Medicare, and to align incentives for beneficiaries, clinicians, and accountable organizations so that participation grows. We particularly welcome allowing eligible ACOs to reduce or eliminate beneficiary cost sharing for high-value Part B services, an important person-centered tool that can improve access to primary care and preventive services. We also welcome the rule’s burden-reduction improvements, including refinements to Medicare CQM reporting and proposals to align the reporting population with assigned beneficiaries, which would reduce reporting complexity and help ACOs meet existing data-completeness requirements. NCQA encourages CMS to implement these changes in ways that produce measurable improvements in outcomes, access, continuity, and value rather than added fragmentation.
As more beneficiaries enter accountable relationships, measurement should evolve from documenting isolated services to assessing whether accountable organizations improve health and function over time, strengthen continuity and coordination, prevent avoidable utilization, and deliver value across the full patient journey. CMS should align these outcomes across the Shared Savings Program, primary care payment, and MIPS Value Pathways (MVPs) so that growth in accountable care reduces program fragmentation.
Preserve accountability for behavioral health and prevention in APP Plus
NCQA shares CMS’s commitment to a harmonious set of quality measures and welcomes the rule’s broader effort to reduce ACO reporting burden. We hold ourselves to the same standard, as evidenced in our proposed retirement of an initial set of HEDIS measures for MY 2027. To guide our decisions, we applied clear criteria of an actionable signal relative to the measure’s reporting burden. Notably, where we retire measures in behavioral health and substance use, we are explicit that this does not signal a retreat; our commitment remains steadfast, and we sustain accountability through better measurement rather than by leaving a gap.
We apply that same lens to APP Plus. Before removing Initiation and Engagement of Substance Use Disorder Treatment and Adult Immunization Status measures, CMS should demonstrate whether the remaining APP Plus portfolio, a renovated measure or another required reporting mechanism, provides a sufficiently actionable signal for substance-use treatment engagement and adult immunization, domains that remain central to Medicare population health and to CMS’s own prevention priorities. Unlike descriptive measures that can be retired without loss of signal, these are actionable measures; if no sufficient signal remains, CMS should retain them or identify a stronger replacement and transition pathway to prevent an accountability gap for ACO populations. NCQA would welcome contributing the criteria and evidence to support this analysis as an independent technical partner.
Support the Medicare eCQM pathway with aligned incentives
NCQA supports establishing Medicare eCQMs as a new collection type, including nationally recognized NCQA-stewarded measures, as a pragmatic step toward digital reporting. To succeed, program incentives and scoring must not disadvantage organizations that adopt Medicare eCQMs and FHIR-based reporting relative to legacy pathways.
Quality Payment Program and the MVP Transition
NCQA strongly supports CMS’s transition from traditional MIPS toward MVPs and the sunset of legacy MIPS reporting, among the clearest expressions in the rule of the shift toward outcomes over process, harmonized measures, and reduced burden, priorities our convenings identified as the field’s highest. Organizing measurement around specialties and conditions, and introducing MIPS Core Measures, moves the program toward better accountability. We are especially encouraged by the condition-focused MVPs for diabetes and hypertension and offer three recommendations to strengthen this architecture.
Create a parsimonious core of outcome-aligned digital measures
As CMS populates MVPs and defines core measures, it should draw on established, standardized, nationally recognized eCQMs and digital quality measures already embedded in clinician workflows. We encourage CMS to continue aligning core measures with the Universal Foundation and not exclude clinically meaningful measures based on collection type alone. This reduces burden, improves comparability, and reinforces the digital transition.
Retain cross-cutting accountability for the outcomes that matter
As legacy MIPS sunsets, CMS should retain accountability for prevention, behavioral health, chronic disease, patient experience, and function, so simplification sharpens the signals that matter. Person-centered outcome measures support whether patients actually improve; NCQA’s Person-Centered Outcome (PCO) measures, approved for HEDIS MY 2027 with a supporting FHIR implementation guide, assess whether patients’ health goals are identified, followed up on, and achieved. A simple discipline reinforces the point: a screening result without documented follow-up is documentation, not quality. CMS should keep follow-up measures while retiring pure checkbox measures.
Connect MVPs to the rest of Medicare accountability
An MVP should not become another self-contained reporting product. CMS should define how MVP measures relate to ACO, hospital, health-plan, and other Medicare accountability, so the same clinical concept is not specified and implemented differently across programs. Our convenings identified this definitional drift as one of the largest sources of provider burden.
FHIR-Based Digital Quality Measurement RFI
NCQA strongly supports CMS’s vision for a modernized, interoperable quality measurement infrastructure, and offers this input from the vantage point of having digitized the full HEDIS measure portfolio and built the transition roadmap the field is now navigating. The challenge ahead is adoption at scale, and CMS’s role in setting clear standards and supporting the transition is the difference between it succeeding broadly or stalling. Our multi-year implementation experience, our data-quality program, and our convenings point to three lessons that should shape CMS’s approach.
Stage the transition and parallel-test to build trust
Digital measures are achievable, and confidence comes from demonstrating parity with traditional measures through comparative testing before organizations transition. In practice, this is a two-to-three-year journey of data preparation, validation, and parallel testing; CMS’s proposed PY 2028 transition and PY 2030 mandatory timeline is realistic only if it is staged and adequately supported. This is borne out in current practice: in recent FHIR digital-measure pilot testing across primary care sites, the most consistent finding was that a specification alone is not enough; organizations need toolkits, technical guidance, and workflow integration to succeed.
Treat data quality as foundational, and shift validation upstream
Data is the hardest part of digital measurement, and EHR certification does not equal data that is fit for use. NCQA is embarking on a path to modernize validation by shifting it upstream, assessing the quality of data at the source rather than relying solely on manual primary source verification, which does not scale in a digital environment. Our Data Quality Solutions framework comprises more than 100 specifications spanning completeness, conformance, plausibility, stability, integrity, provenance, and timeliness. We recommend CMS pair FHIR exchange requirements with explicit data-quality assessment along these dimensions for FHIR-based measures. The breadth of interest in this approach, from CMS and public health agencies to major plans, data aggregators, and EHR vendors, reinforces the need for consistent, transparent methods to determine whether interoperable clinical data are fit for measurement, accountability, and improvement.
Engineer the transition for all
Our advisory panels and public comment consistently find that readiness is uneven and heavily dependent on EHR vendors, and that payer alignment is the single biggest enabler of FHIR feasibility. FHIR adoption today is most advanced among large plans, systems, and vendors, and weakest in the small, rural, and safety-net settings, and among the dual-eligible and low-income populations, where the need is greatest. The field cannot allow modernization to become another tool that serves the already served. If the costs and operational complexity of digital reporting fall disproportionately on smaller, rural, safety-net, and resource-constrained organizations, while legacy pathways remain more attractive, the transition risks widening existing disparities in participation and digital readiness. CMS should provide clear implementation guidance, testing opportunities, adequate transition periods, and ensure that MSSP incentives support adoption of Medicare eCQMs and FHIR-based reporting. As CMS advances toward mandatory digital quality measurement, organizations investing in the infrastructure required for that transition should not be rewarded less favorably than those remaining on legacy reporting pathways. NCQA welcomes serving as an independent technical partner on measure specification, testing, certification, and data-quality validation, and we support CMS’s exploration of future performance-based measures for electronic prior authorization that prioritize timeliness, transparency, and workflow efficiency.
Specialty Care in the Shared Savings Program RFI
NCQA supports strengthening specialty accountability within the Shared Savings Program through measurable coordination capabilities, timely communication, exchange of clinical information, closed-loop follow-up, and shared care plans supported by FHIR-enabled exchange. As CMS extends accountability into specialty care and new MVPs, we encourage it to align these efforts around shared concepts and measures in access, coordination, outcomes, appropriateness, and value rather than parallel measure sets, since our convenings identified definitional drift across programs as a leading source of burden. NCQA welcomes serving as an independent technical partner on that alignment.
Future of Clinical Coding Standards RFI
Because CPT codes underpin most quality reporting, including HEDIS, changes to coding standards carry direct downstream implications for how care is measured. On maternity coding, we recommend CMS adopt the restructured CPT maternity care codes rather than create new HCPCS G-codes. New G-codes could create billing variation that weakens the reliability of quality signals, whereas the restructured CPT codes offer greater specificity and better connect perinatal care processes to outcomes. More broadly, we encourage CMS to prioritize stability, transparency, adequate transition time, and early engagement with measure developers and health IT stakeholders, so coding changes strengthen the infrastructure for value-based care, prevention, and digital measurement.
Conclusion
This is an ambitious and encouraging rule. Its greatest promise lies in connecting adequate investment in comprehensive, team-based primary care with expanded, accessible accountable care, measure harmonization, and timely, trustworthy data, so that these elements reinforce one another. Informed by our measurement journey, our convenings, and our program-development experience, NCQA is committed to helping CMS turn this direction into durable, measurable improvement for all beneficiaries, and we welcome the opportunity to continue the dialogue.
Thank you for your consideration. If you have any questions, please contact Kristine Thurston Toppe, Vice President of State Affairs, Public Policy, at (202) 955-1744 or toppe@ncqa.org.
Sincerely,
Vivek K. Garg, MD, MBA
President & CEO
National Committee for Quality Assurance
