July 30, 2025
The National Committee for Quality Assurance (NCQA) commends the Centers for Medicare & Medicaid Services (CMS) for publishing the Interoperability Framework and Health Technology Ecosystem—a comprehensive, forward-looking approach to improving how health data is exchanged and used to support care.
At its core, CMS’s framework acknowledges a fundamental truth: better health care depends on better information. This framework marks an important step toward enabling collaboration and advancing a more seamless, data-enabled healthcare system where care is connected, proactive and effective for patients.
A Strong Foundation for Digital Quality
NCQA is particularly encouraged by the framework’s emphasis on data standardization and real-time data exchange, which are essential building blocks for a modern quality infrastructure. Today’s quality measurement processes remain too dependent on outdated standards such as the Quality Data Model (QDM) and Quality Reporting Document Architecture (QRDA), along with manual interpretation of quality specifications and nonstandard data formats. These inefficiencies create unnecessary friction and cost, while limiting the ability of those that deliver and manage care to act on timely insights.
The CMS interoperability vision helps address these challenges directly. By supporting consistent implementation of Fast Healthcare Interoperability Resources (FHIR) standards across payers and providers—and by encouraging collaboration across the digital health ecosystem—the industry can catalyze a shift to shared, interoperable infrastructure. This is precisely the type of environment in which quality improvement can thrive.
Digital quality is not simply about automating what exists today. It’s about transforming the measurement model using standardized data and logic that can be embedded across clinical, operational, and payment workflows. When powered by standards like FHIR and Clinical Quality Language (CQL), quality measurement becomes more accurate and more actionable. The CMS vision helps make transformation achievable at scale.
Advancements in Digital Quality
For the past several years, NCQA has invested deeply in digital quality innovation. We’ve led the development of digitalized Healthcare Effectiveness Data and Information Set (HEDIS®) measures using FHIR and Clinical Quality Language (CQL), enabling organizations to leverage digitally specified measures and standards-conformant data that reduces reliance on manual translation and improves alignment across stakeholders. In parallel, NCQA developed FHIR-based data validation to assess the integrity of the data used for HEDIS health plan reporting and broader quality purposes.
Early adopters of digital quality measures are already beginning to implement digital HEDIS measures in their workflows. While we are still several years away from full-scale digital HEDIS reporting, the shift is well underway. CMS’s framework reinforces this trajectory and validates the industry’s growing investment in FHIR-based quality measurement as foundational to the future of quality.
Advancing Trust and Innovation
Equally important is the role of trust. Fragmented systems and inconsistent data models can erode confidence in quality and hinder collaboration. CMS’s call to coalesce around shared standards and shared expectations is not just a technical recommendation, it is a trust-building exercise that will help the industry move forward together.
A well-governed, standards-based ecosystem enables more agile quality improvement, smoother integration of clinical and administrative data, and the potential to embed quality into the fabric of care, whether that’s through real-time decision support, advanced analytics, or payment model design.
NCQA’s Commitment to a Shared Vision
As a leader in quality measurement, accreditation, and standards development, NCQA is committed to working alongside CMS, health plans, providers, technology vendors, and state agencies to bring this vision to life. We believe the interoperability framework complements our ongoing efforts to support digital measurement implementation, validate data flows for accuracy, completeness and usability, and help organizations modernize their quality infrastructure.
As organizations adopt and operationalize this new digital health ecosystem, there is a critical opportunity to embed quality into its foundation. We welcome partners and collaborators to explore how digital HEDIS measure content can be integrated and scaled across the ecosystem to drive smarter, real-time quality improvement. We encourage organizations to engage NCQA by:
- Using Digital Quality Measure Content: Organizations can engage NCQA to embed digital quality measure content directly into existing quality monitoring, quality improvement and care delivery processes and applications. This enables quality to be built into clinical workflows, reduces redundant implementation across programs and breaks down silos between quality reporting, care management and analytics—driving more efficient operations and ultimately helping people receive better, more coordinated care.
- Improving Data Validation Methods: NCQA is developing new ways to automate and scale clinical data quality assessments, with a goal of supporting continuous, standards-based evaluation of clinical data to reduce the burden of manual primary source verification and strengthen trust in whether data are “fit-for-use” for HEDIS and other quality programs. Later this year, we’ll begin working with early partners to validate and pilot this approach. If you’re interested, we invite you to connect with us and explore opportunities to participate.
A healthier population and a more efficient healthcare system depend on smarter use of data to measure and improve care. Digital quality is a key enabler of that vision, transforming how we track performance, reduce burden and support better outcomes. The CMS framework is a meaningful catalyst, and NCQA is committed to working with partners to realize its full potential.
About NCQA
NCQA is a private, nonprofit organization dedicated to improving health care quality. NCQA Accredits and Certifies a wide range of health care organizations. It also Recognizes clinicians and practices in key areas of performance. NCQA’s Healthcare Effectiveness Data and Information Set (HEDIS®) is the most widely used performance measurement tool in health care. NCQA’s website (ncqa.org) contains information to help consumers, employers and others make informed health care choices. NCQA can also be found at Twitter/X @ncqa and on LinkedIn at linkedin.com/company/ncqa.
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