Cotiviti Blog

HEDIS MY 2027 Public Comment: What to know

Written by Samantha Davis | Mar 10, 2026 6:19:46 PM

Each year, the HEDIS® public comment period offers health plans a critical opportunity to understand what’s changing and to influence what comes next. For Measurement Year (MY) 2027, the National Committee for Quality Assurance (NCQA) is proposing a wide range of updates that span finalized measure changes, updates still open for comment, and several new measures that signal the continued shift toward digital and outcomes‑focused measurement. Simultaneously, the Centers for Medicare & Medicaid Services (CMS) is proposing measure retirements and additions for the Exchange MY 2026 Quality Rating System (QRS) reporting program.

Below is a concise breakdown of what health plans need to know now, and how to prepare for what’s ahead.

Finalized measure changes

NCQA’s annual Notification of Changes outlines updates that are already finalized and not open for public comment. This year’s notification spans three measurement years, creating both near‑term and long‑term planning considerations.

HEDIS MY 2026

NCQA will add new LOINC codes to the Cervical Cancer Screening (CCS-E) measure to support self‑collected HPV samples, reflecting expanded screening pathways. NCQA also pulled back earlier changes to the Social Needs Screening (SNS-E) measure, reverting to reliance on LOINC survey codes and LOINC Answer responses following physician fee schedule updates.

HEDIS MY 2027

NCQA announced revisions to its hybrid reporting transition plans. The Weight Assessment and Counseling for Nutrition and Physical Activity for Children and Adolescents (WCC) measure will remain hybrid through 2029 and retire alongside its replacement measure, with no overlap year. NCQA also confirmed that MY 2027 Volume 2 specifications will be released on August 3, and that long‑term services and supports measures will move to a FHIR‑based specification layout without changing reporting methodology.

HEDIS MY 2028

Additional hybrid transitions have been delayed or restructured, with the Prenatal and Postpartum Care (PPC) measure being replaced by an ECDS and risk-based measure in 2028 with no overlap year. The Transitions of Care (TRC) and Care for Older Adults (COA) replacement measures have been delayed to MY 2028 and will have one optional reporting year before the hybrid measures are retired in MY 2029. NCQA also plans to allow use of denied claims in 21 measures that previously excluded them, and plans to provide greater clarity on data source identification and timing of measure requirements in future Volume 2 specifications.

Proposed measure changes

Several changes are open for public comment. From CMS, the draft 2026 Call Letter for QRS proposes retiring Asthma Medication Ratio (AMR) and Medical Assistance with Smoking and Tobacco Use Cessation (MSC), replacing them with two new HEDIS electronic clinical data systems (ECDS) measures: Follow-Up After Acute and Urgent Care Visits for Asthma (AAF-E) and Tobacco Use Screening and Cessation Intervention (TSC-E). CMS also plans to remove Childhood Immunization Status (CIS-E) and Immunization for Adolescents (IMA-E) from QRS reporting.

NCQA’s proposed MY 2027 updates include expanding the Pneumococcal indicator in Adult Immunization Status (AIS-E) to members ages 50 and older, aligning with updated clinical recommendations. The organization also proposes expanding Emergency Department Utilization (EDU) reporting to Medicaid members aged 18-64. Medicaid enrollees with nine or more ED visits in the measurement year would be excluded as outliers.

Another significant proposal is the redesign of the Pharmacotherapy Management of COPD Exacerbation (PCE) measure. NCQA is shifting from a denominator count of COPD exacerbation events to instead a count of members with exacerbation events. It is also proposing a new exclusion for members with two asthma diagnoses in the measurement year or year prior. The measure is also reduced from two rates into one, measuring for members who had at least one short-acting and one long-acting COPD medication any time in the measurement year.

Proposed new measures

For MY 2027, NCQA is proposing seven new measures, many of which highlight ongoing data availability challenges.

Continuous Glucose Monitoring for Patients With Diabetes (CGD-E)

This measure would document utilization of continuous glucose monitoring for members aged 18–75 in commercial, Medicare, and Medicaid populations.

  • Members would be eligible for the measure if they have been diagnosed with diabetes and if they have evidence of using insulin, either due to a type 1 diabetes diagnosis or insulin medication.
  • NCQA notes concern that evidence of glucose monitoring within real-world data sources may be missing, incomplete, or located in unstructured formats, making it difficult for health plans to use for reporting.
  • A member would be eligible for this measure if they have at least one positive stool-based colorectal cancer screening test result from July 1 of the prior year through June 30 of the measurement year.
  • NCQA’s feasibility analysis notes that stool-based test results are not often captured in coded, discrete fields, impacting reliability and usability of the data.
  • A member would be compliant for the measure if they have a follow-up colonoscopy on or within 180 days following their earliest positive stool-based colorectal cancer screening test result.
  • Eligible members would be compliant for the screening numerator if they have an IPV screening with a documented result between January 1 and December 24 of the measurement year.
  • NCQA’s analysis indicates that IPV screening results are not often present in structured fields, and are more likely to be located in free text areas, if at all in the electronic health record.
  • Members with positive screening findings would need to receive follow-up care on or within seven days of the first positive screening.
  • The Goal Identification measure would consider a member to be compliant if they have a goal documented between August 1 of the prior year through July 31 of the measurement year.
    • This would be calculated by the presence of a goal attainment scaling (GAS) or patient-reported outcome measure (PROM) goal with a populated goal domain on the same day, as well as a care plan documented within seven days of the goal.
    • NCQA notes that goal domains do not all have terminology standards available, but that it is in the process of submitting standard LOINC codes for these domains, which NCQA expects to be formalized prior to the measures being included in HEDIS reporting.
  • The Goal Follow-Up measure requires a member to meet both the numerator criteria for goal identification, as well as evidence of goal follow-up in the 14–180 days following goal identification.
    • NCQA indicates that goal tools and score results are not consistently documented in structured fields available to health plans, as well as potential accuracy challenges for tracking goal progress over time.
  • The Goal Achievement measure requires a member to meet the numerator criteria for goal identification, as well as evidence of goal achievement in the 14–180 days following goal identification.
    • Achievement of a goal is determined by evaluating available GAS or PROM scores compared to the baseline goal to check for results indicating expected outcomes or meaningful change.
  • This delivery-based measure includes both deliveries and miscarriages at 14 or more weeks of gestation between December 15 of the prior year through December 14 of the measurement year.
  • Compliance for the screening numerator is based on whether the member had a syphilis screening within either the first trimester, any time from pregnancy start through 14 days after the first pregnancy diagnosis or prenatal visit, or any time from pregnancy start through 30 days after plan enrollment.
  • This measure has similar issues noted in measure testing for data availability, so NCQA asks in the public comment if plans may have access to syphilis screening results which could be mapped to SNOMED codes for measure processing.
  • Deliveries with a positive syphilis screening are included in the second denominator, and would be considered compliant from either a negative confirmatory syphilis screening result on or within five days of the first positive screening, or evidence of penicillin treatment on or within 14 days of the first positive screening.

Follow‑Up After Positive Colorectal Cancer Non‑Invasive Screening Test (COF-E)

This measure would capture the percentage of members aged 45–85 who received a colonoscopy after a positive colorectal cancer non-invasive screening test in commercial, Medicare, and Medicaid populations.

Intimate Partner Violence Screening and Follow‑Up (PSV-E)

This measure would evaluate the percentage of members aged 12–64 who were screened for intimate partner violence (IPV), and if found positive, who received follow-up care within seven days in commercial and Medicaid populations.

Person-Centered Outcome measures (GID-E, GIF-E and GIA-E)

These measures would assess the percentage of members 18 and older with a complex care need who set a person-centered outcome goal, followed up on the goal, and achieved the goal for Medicare Special Needs Plans (SNPs).

Prenatal Syphilis Screening and Follow‑Up (PSF-E)

This measure would evaluate the percentage of deliveries screened for syphilis during pregnancy, and if screened positive, that received appropriate follow-up care for commercial and Medicaid populations.

Together, these measures underscore that even with the shift to digital measurement using industry-standard data formats, data transformation on electronic data feeds is likely to still be required to make the data usable for HEDIS reporting.

Action plan for health plans

With multiple timelines and overlapping changes, now is the time for proactive planning. Health plans should review all public comment materials from CMS and NCQA, including NCQA’s proposed value set directory, which is essential for evaluating data feasibility. Public comments are due Friday, March 13 for NCQA and Friday, March 20 for CMS.

Plans can also begin early analysis of their data repositories to identify gaps, particularly for structured lab results, screening questionnaires, and member goals. Later this year, once MY 2027 Volume 2 specifications are released, organizations should balance MY 2026 readiness with forward‑looking strategies to support gap closure and data capture in 2027. Consider the following short-term steps and long-term strategies:

Next week

Next 150 days

Next 365 days

  • Download and review the NCQA Public Comment value set directory
  • Comment via NCQA’s PCS system on the proposed new and changed measures by March 13
  • Email CMS on the proposed QRS Exchange program changes by March 20
  • Locate data sources for CCS-E self-reported cervical cancer screenings
  • Estimate measure impact for pneumococcal vaccinations in ages 50-64 and ED utilization for Medicaid populations
  • Evaluate for potential data gaps with new measure proposed value sets
  • Read the MY 2027 HEDIS Volume 2 technical specs when released on August 3
  • Capture supplemental and clinical data for finalized new MY 2027 measures
  • Join Cotiviti’s Quality Decoded MY 2027 HEDIS Tech Spec review on September 10

Webinar: Decoding the HEDIS Public Comment Period

For a deeper dive into these changes and practical guidance on submitting effective comments, watch our recent on‑demand Quality Decoded webinar, and sign up for our ongoing series as we continue to break down critical HEDIS topics throughout the year.

HEDIS® is a registered trademark of the National Committee for Quality Assurance.