We are pleased to share that CMS has proposed the inclusion of five new Functional Improvement quality measures, developed and stewarded by Patient360 and Limber/Net Health, as MIPS Clinical Quality Measures (CQMs) for CY 2027.
These candidate patient-reported outcome-based performance measures (PRO-PMs) are proposed to replace seven legacy FOTO Functional Status Change measures (Quality IDs 217–222 and 478) across Traditional MIPS, within the PT/OT and Chiropractic specialty sets, as well as the Rehabilitative Support MVP.
For quality leaders and clinicians across our network, here are a few key takeaways:
- Modern Measurement Science: Each candidate PRO-PM is based on a PROMIS® patient-reported outcome measure (PROM). Such PROMs leverage modern measurement methods, offering key advantages such as valid interval scaling assumptions, superior scale coverage, unidimensionality for valid score interpretation, and high measurement precision.
- Reduced Patient Burden: These methods also allow for PROMIS® PROMs to be administered via computerized adaptive testing (CAT), which minimizes patient burden by reducing the number of questions required to capture an accurate functional score.
- PROM Administration Alternatives: When CAT is unavailable, PROMIS® PROM short forms serve as the recommended alternative. Additionally, alternative “legacy” PROMs are supported through validated crosswalks between legacy instruments and PROMIS® PROMs.
- Robust Risk Adjustment: Our measure development team developed rigorous risk adjustment models to enable fair comparisons across clinicians. They further performed rigorous testing to ensure that any variations in the likelihood of reaching performance thresholds when using different PROMs are accounted for within the risk-adjustment model.
- Predicted Moderate Clinical Improvement (P-MCI): P-MCI represents a patient-specific, risk adjusted-predicted amount of improvement in the PROM score. Each patient’s P-MCI is estimated using risk adjustment factors associated with clinical improvement that fall outside the clinician’s control.
- Driving Meaningful Change: Musculoskeletal conditions significantly impair quality of life and productivity while driving high healthcare costs. These measures provide clinically actionable data to inform patient-centered decision-making and facilitate functional improvement.
Should CMS finalize these proposed measures, we encourage stakeholders to watch for important implementation details within the full measure specifications (to be published by CMS with or soon after the Medicare Physician Fee Schedule Final Rule is published, typically late October/early November):
- Measure calculation steps and instructions.
- Guidance on operationalizing PROMs within routine clinical workflows.
- Best practice standards for administering PROMs to patients to reduce risks for bias.
- Details surrounding the predicted outcome, P-MCI.
While the initial measure versions target episode-based care delivered by non-surgical musculoskeletal care providers, the Patient360 – Limber/Net Health co-steward team welcomes the opportunity to partner with CMS to expand their application to additional care settings and provider types in the future.
