Comment on CMS-2026-2377-0002

CMS Should Require EHR Vendors to Support All CMS-Approved Quality Reporting Methodologies If CMS finalizes a new quality reporting methodology, measure set, or reporting architecture, CMS should require certified EHR vendors to support that methodology as a condition of certification and within a reasonable implementation timeframe. Today, many physician practices, rural hospitals, and ACO participant organizations have invested substantial resources in EHR systems, quality dashboards, and custom reporting tools that are aligned to existing CMS reporting programs. Unfortunately, providers often have little influence over the development priorities of their EHR vendors. We have encountered situations in which EHR vendors have indicated that because their product supports one CMS-approved quality reporting methodology, such as eCQMs, they are not obligated to support alternative CMS reporting pathways or future quality measurement approaches. As a result, providers may find themselves in the untenable position of being required to report under a specific methodology that their certified EHR system does not support (for instance, a small ACO cannot afford a 3rd party to deduplicate eCQM data, so most choose Medicare CQM reporting, but the EHR vendor won't provide MCQM assistance in report generation). In many cases, if even possible, obtaining "additional" reporting functionality requires expensive custom development, third-party reporting solutions, new interfaces, or may simply not be feasible due to the extremely long timeline of the vendor's product roadmap. CMS should recognize that providers should not be penalized for technology limitations that are entirely outside their control. If CMS creates new reporting requirements, digital quality measures, FHIR-based reporting standards, or alternative quality measurement methodologies, EHR vendors should be required to demonstrate support for ALL of those reporting methods within a defined timeframe. A provider's ability to succeed in federal quality programs should not depend upon whether their vendor chooses to develop a particular reporting capability that their ACO cannot financially or operationally support. Without such a requirement, CMS risks creating significant inequities across providers. Organizations that happen to use a vendor supporting CMS's preferred methodology would face minimal disruption, while others could be forced into costly system modifications, vendor negotiations, or wholesale technology replacements. This challenge is particularly acute for rural ACOs, Critical Access Hospitals, Rural Health Clinics, and small independent practices that lack the financial resources and market leverage necessary to compel vendor development. CMS should therefore align any future reporting changes with corresponding vendor accountability requirements so that the burden of compliance is shared across the health IT ecosystem rather than being imposed solely on providers. Doing so would reduce unnecessary administrative costs, improve adoption of new reporting models, and help ensure that healthcare resources remain focused on patient care rather than technology remediation efforts. It is unacceptable for CMS to produce alternative reporting pathways for REQUIRED quality reporting, and then state they are not responsible for holding EHR vendors accountable as part of cEHR validation. If a method such as MCQM is valid, but an EHR vendor won't / can't support it, then the clinic and/or ACO should be given a technical exemption for quality reporting until the vendor is able to support it.