dQMs Are Coming: What the CMS Digital Quality Measurement Roadmap Means for Health Plans

The quality measurement landscape is undergoing its most significant structural shift in decades. The Centers for Medicare & Medicaid Services (CMS) and the National Committee for Quality Assurance (NCQA) are executing coordinated roadmaps to transition all quality measurement to digital, standards-based, FHIR-enabled digital quality measures (dQMs). Both agencies have published timelines, and both have set hard deadlines. The work for health plans is no longer to decide whether to participate, but to be ready when the deadlines arrive.

What dQMs change about measurement

NCQA defines digital quality measurement as the use of standardized, digital data from one or more sources of health information that is captured and exchanged via interoperable systems, paired with quality measure specifications that are standards-based (NCQA, Digital Quality Overview, 2024). The definition does the work of three legacy distinctions at once.

• Data source. Instead of relying on claims and manually abstracted charts, dQMs pull from EHRs, health information exchanges (HIEs), registries, case management systems, and administrative data, all exchanged through standardized APIs.
• Measure specification. dQMs are authored in Clinical Quality Language (CQL) and expressed as FHIR resources, making them computable, shareable, and executable across systems without translation.
• Reporting. Rather than annual batch submissions, dQMs enable near-real-time quality assessment, with data flowing continuously through FHIR APIs.

CMS articulates the goal directly: it is transitioning all quality measures used in its reporting programs to digital quality measures (eCQI Resource Center, About dQMs, 2024). This is not an incremental improvement. It is a systemic transformation that asks a plan to re-platform, not to optimize.

eCQM and dQM diverge on interoperability, not definition

One of the most common points of confusion in the quality measurement community is the distinction between electronic Clinical Quality Measures (eCQMs) and digital Quality Measures (dQMs). The terms are sometimes used interchangeably. They describe different stages in the evolution of electronic measurement.

CMS finalized its eCQM definition as measures specified in a standard electronic format that use data electronically extracted from electronic health records and health information technology systems to measure the quality of health care provided (CMS, eCQM Basics, 2024). eCQMs were a critical first step: digitizing the measure specification and sourcing data from EHRs. They remain largely siloed within individual provider systems.

dQMs go further. By mandating FHIR as the exchange standard and CQL as the expression language, dQMs are designed to be computable across different systems, data sources, and use cases. A single dQM specification, once authored, can be deployed across health plans, providers, and regulators without re-implementation. That portability is the structural change, not a faster version of the old workflow.

FHIR is the connective tissue, not a recommendation

FHIR (Fast Healthcare Interoperability Resources) is the connective tissue of the dQM architecture. The HL7 FHIR standard defines RESTful APIs and resource models for healthcare data exchange, and it is now the mandated standard for quality measurement data exchange under CMS regulations.

The HL7 Da Vinci Project’s Data Exchange for Quality Measures (DEQM) Implementation Guide provides the technical specification for how quality data should be exchanged using FHIR (HL7, DEQM IG, 2024). Key FHIR-based quality use cases include:

• Individual reporting. A provider submits quality data for a specific patient to a payer or registry.
• Summary reporting. A provider or health plan submits aggregate quality measure results.
• Gaps in care reporting. Payers identify care gaps and share them with providers via FHIR APIs.
• Attribution and enrollment. The Implementation Guide defines which patients are attributed to which providers for measurement purposes.

The CMS Quality Measure Development Plan 2024 Annual Report notes that CMS is actively supporting the transition of measures to dQMs and conversion to the FHIR format (CMS, Quality Measure Development Plan 2024 Annual Report, 2024). FHIR is not a recommendation in that sentence. It is the operational standard toward which CMS programs are actively migrating.

NCQA plans to retire hybrid HEDIS by MY 2029

For health plans, the most immediate impact of the digital quality transition is in HEDIS reporting. NCQA has been building toward this for years through its Electronic Clinical Data Systems (ECDS) reporting standard, a structured way for health plans to collect and submit quality measure data that goes beyond traditional administrative and hybrid methods.

NCQA’s vision is explicit: the use of digital quality measures (dQMs), delivered through a multi-phase approach toward fully automated measurement (NCQA, Digital Quality Transition, 2024). Most significantly, NCQA has announced that it plans to phase out the hybrid reporting method by MY 2029 (NCQA, Proposed Timeline, Dec 2024).

The proposed elimination of hybrid HEDIS would upend plans that built their quality infrastructure around annual chart chase. Under NCQA’s proposal, every HEDIS measure would be sourced from structured, interoperable digital data: claims, EHR data via FHIR, HIEs, and other ECDS-allowable sources. The colorectal cancer screening guide walks through one measure that has already begun this transition under ECDS, and the pattern generalizes.

Plans that manually chart review for the numerator of measures like COL today are running a workflow whose shelf life is now numbered in months, not years. The same chart evidence, ingested upstream as structured FHIR data, becomes the ECDS source of record. The labor does not vanish; it migrates from retrospective abstraction to prospective data integration.

CMS has been building the dQM roadmap since 2014

On March 11, 2026, CMS published the CCSQ FY2025-2028 Strategic Roadmap, outlining five strategic goals: Prevention, Quality and Safety, Coverage Innovation, Data and Technology, and Burden Reduction (CMS, CCSQ Strategic Roadmap, Mar 2026). Within the Data and Technology pillar, CMS explicitly commits to advancing digital quality measures across CMS Quality Reporting and Value-Based Purchasing programs.

The CMS dQM roadmap started well before 2026. Key milestones:

• 2014. The Improving Medicare Post-Acute Care Transformation (IMPACT) Act required standardized patient assessment data and quality measure reporting across post-acute care settings, setting the stage for standardized electronic measurement.
• 2022. CMS launched the CMS National Quality Strategy, establishing digital quality measurement as a foundational goal (CMS, Quality in Motion, 2022).
• 2023. CMS began publicly referencing its dQM Strategic Roadmap in rulemaking, signaling the transition from pilots to policy.
• 2024. The CY 2025 Medicare Physician Fee Schedule Final Rule referenced the Digital Quality Measurement (dQM) Strategic Roadmap and positioned Medicare CQMs as a transition mechanism (CMS, CY 2025 PFS Final Rule, Nov 2024).
• 2025-2026. CMS expanded dQM requirements into Medicaid Core Sets, Home Health proposed rules, and hospital quality programs.

The CMS strategy operates on multiple tracks simultaneously, across Medicare, Medicaid, and the Marketplace. The clear message: digital quality is not a single-program experiment. It is the unified direction for all CMS quality measurement.

The Medicaid Core Sets extend dQMs to 90 million Americans

Much of the industry’s attention has focused on Medicare and HEDIS. One of the most consequential dQM mandates is happening in Medicaid. CMS has introduced digital quality measure reporting requirements for the Child Core Set, Adult Core Set, and Health Home Core Set, with mandatory reporting beginning in phases (CMS, Medicaid dQM Fact Sheet, 2026).

The Medicaid dQM transition is significant for three reasons:

• Scale. Medicaid covers more than 90 million Americans. The Core Sets mandate affects every state Medicaid program and the managed care organizations (MCOs) that serve them.
• Infrastructure gap. Many state Medicaid agencies and MCOs have less mature data infrastructure than large commercial plans or Medicare Advantage organizations, making the transition especially challenging.
• Precedent. The Medicaid mandate establishes that dQMs are not just for high-resource programs. They are the standard for all CMS quality reporting, regardless of program size or complexity.

CMS’s technical assistance resources for states explicitly frame the 2026 Core Sets as a bridge year for digital quality measurement, introducing ECDS specifications and FHIR-based data exchange requirements that will only expand in subsequent years (CMS, Transitioning to Digital Quality Measures in the 2026 Core Sets, 2026).

What this means for health plans

The convergence of CMS’s dQM roadmap and NCQA’s HEDIS transition timeline creates a clear action window for health plans. Five implications follow.

Manual chart review is becoming unsustainable, and soon non-compliant

NCQA’s proposed MY 2029 hybrid HEDIS sunset would give plans that rely on manual chart abstraction a firm deadline to transition. For a typical health plan, chart review for HEDIS can consume hundreds of thousands of dollars and thousands of staff hours annually. The dQM transition is not only a regulatory requirement. It is an opportunity to replace expensive, retrospective processes with automated, continuous measurement. Our AI chart review post lays out what the transition year looks like for the operations team. Delaying that transition erases those savings.

FHIR API capability is no longer optional

Both CMS and NCQA are standardizing on FHIR as the exchange format for quality data. Health plans need production-grade FHIR server infrastructure capable of consuming, storing, and querying clinical data at scale. This includes supporting key FHIR Implementation Guides such as the Da Vinci DEQM IG and bulk FHIR access patterns for population-level measurement. FHIR is infrastructure that compounds: the same server that powers dQM also enables payer-provider data exchange, value-based care analytics, and member engagement.

Diverse data sources must be unified

dQMs pull from multiple sources: claims, EHR data, HIE feeds, case management records, and patient-reported outcomes. Plans need data ingestion and normalization pipelines that can harmonize these diverse sources into a consistent, queryable format. As NCQA notes, administrative data sources remain important for HEDIS, and they need to be converted to FHIR for digital quality (NCQA, Digital Quality Overview, 2024). The operational question is not whether a source is structured, but whether the plan can render it as FHIR before measurement.

The window to prepare is shrinking

MY 2029 sounds distant. For health plans that have not started their digital quality journey, the runway is tight. Standing up FHIR infrastructure, negotiating data-sharing agreements with provider networks, normalizing multi-source clinical data, and validating dQM computation all require multi-year investments. Plans that start now will have time to iterate. Plans that wait will face a compliance scramble, and a costly one. A reasonable benchmark: plans ready for full MY 2027 ECDS reporting will spend 2028 iterating; plans that wait until 2027 to start will spend 2028 scrambling and 2029 explaining.

Quality measurement becomes continuous

Perhaps the most transformative aspect of dQMs is the shift from annual, retrospective measurement to continuous, prospective quality assessment. When quality data flows through FHIR APIs in near-real-time, plans can identify care gaps as they emerge, not 12 months later during HEDIS season. This enables point-of-care interventions, provider feedback loops, and population health management strategies that are simply impossible with today’s once-a-year measurement cycle. The Quality Health quality portal for bi-directional data exchange was built for this paradigm: measure performance tracked against the live data feed, not the prior year’s PDF.

Position now for the transition

The health plans that will navigate this transition most successfully share several characteristics.

• They treat dQM as a strategic investment, not a compliance exercise. The same FHIR infrastructure that powers dQM also enables value-based care analytics, clinical data integration, and member engagement, creating value far beyond regulatory reporting.
• They invest in platforms that can ingest and normalize both EMR and claims data. As NCQA emphasizes, not all clinical data will be available in the FHIR format right away. During the transition to digital quality, significant amounts of data will only be available in other formats (NCQA, Digital Quality Overview, 2024). The ability to work with data in whatever format it arrives, and convert it to FHIR, is essential.
• They build for the future state while operating in the present. For the next several years, plans will exist in a hybrid world: some measures reported via ECDS, some via traditional hybrid methodology, some via administrative-only. Infrastructure must support both paradigms.

The bottom line

The shift to digital quality measures is not a distant regulatory possibility. It is an active, funded, multi-agency transformation with firm timetables. CMS’s CCSQ FY2025-2028 Strategic Roadmap and the Medicaid Core Sets dQM mandate are already in motion. NCQA’s proposed MY 2029 hybrid HEDIS retirement points to the same destination. Taken together, they signal that the era of chart-based quality measurement is drawing to a close.

For health plans, the question is no longer whether to invest in digital quality infrastructure. It is whether they will have it ready in time, or be forced to play catch-up when the deadlines arrive. Plans that build now will own the infrastructure that defines quality measurement for the next decade. Plans that wait will rent it from someone who did.

Sources

• CMS, “Optimal Health for All Within Nation’s Health and Long-Term Care Systems: CCSQ FY2025-2028 Strategic Roadmap,” March 11, 2026. cms.gov
• NCQA, “Digital Quality Transition.” ncqa.org
• NCQA, “Digital Quality Overview.” ncqa.org
• CMS, “Electronic Clinical Quality Measures Basics.” cms.gov
• HL7 International, “Data Exchange for Quality Measures (DEQM) Implementation Guide.” hl7.org
• CMS, “CMS Quality Measure Development Plan: 2024 Annual Report.” cms.gov
• NCQA, “NCQA’s Proposed Timeline for Retiring and Replacing HEDIS Hybrid Measures,” December 2, 2024. ncqa.org
• CMS, “Quality in Motion: CMS National Quality Strategy,” 2022. cms.gov
• CMS, “Calendar Year (CY) 2025 Medicare Physician Fee Schedule Final Rule (CMS-1807-F),” November 1, 2024. cms.gov
• CMS, “Fact Sheet: Digital Quality Measures and Core Sets Reporting.” medicaid.gov
• CMS, “Transitioning to Digital Quality Measures in the 2026 Child, Adult, and Health Home Core Sets.” medicaid.gov
• eCQI Resource Center, “About dQMs: Digital Quality Measures,” healthit.gov. ecqi.healthit.gov