FY 2027 IPPS Final Rule: A Closer Look at Promoting Interoperability

The FY 2027 Inpatient Prospective Payment System (IPPS) final rule does not create a single Promoting Interoperability deadline. Its changes stretch from the 2026 EHR reporting period through the FY 2030 payment determination. For hospital technology teams, the practical question is which changes require attention when.

The Centers for Medicare & Medicaid Services (CMS) published the FY 2027 IPPS final rule on August 4, 2026. The Promoting Interoperability provisions include changes to electronic prior authorization, public health and clinical data exchange, health information exchange measures, certified health IT attestations, and electronic clinical quality measures (eCQMs).

At a glance, the implementation timeline looks like this:

• 2026 EHR reporting period: ONC Direct Review and ONC-Authorized Certification Body Surveillance attestations are removed.
• 2027 EHR reporting period: Electronic Prior Authorization becomes an optional bonus measure, and a new Unique Device Identifiers for Implantable Medical Devices measure begins.
• 2028 EHR reporting period: Electronic Prior Authorization becomes mandatory.
• CY 2028 EHR reporting period: Two eCQMs are added, and three are removed. These correspond with the FY 2030 payment determination.
• 2029 EHR reporting period: Two Support Electronic Referral Loops measures are removed.

CMS summarizes these finalized changes in its FY 2027 IPPS final rule fact sheet.

Electronic Prior Authorization: Use 2027 as a Readiness Year

Electronic prior authorization is the change with the clearest near-term operational runway. CMS finalized the measure as optional for bonus points in the 2027 EHR reporting period and mandatory beginning in 2028 for eligible hospitals and Critical Access Hospitals (CAHs).

At the same time, certain CMS-regulated payers must begin supporting Prior Authorization APIs in 2027. CMS is already urging providers to talk with their EHR vendors about readiness, including implementation plans and workflow implications.

For hospital IT teams, that makes 2027 a useful year for implementation: confirm which systems and payer connections are involved, determine where the workflow begins and ends, and identify what must be tested before the measure becomes mandatory. Hospitals and CAHs that successfully attest “Yes” to the optional Electronic Prior Authorization measure in CY 2027 can also earn 10 bonus points toward their Medicare Promoting Interoperability score. That opportunity may be especially valuable for facilities that have previously struggled—or come close—to meeting the required 80-point threshold.

One distinction is important. The CMS requirement addressed here applies to prior authorization for medical items and services and excludes drugs under the CMS Interoperability and Prior Authorization Final Rule. It should not be assumed to be the same as pharmacy-specific electronic prior authorization workflows.

MEDHOST is actively developing Electronic Prior Authorization capabilities for procedures and services to help customers prepare for these evolving requirements. Customers can contact their Customer Success Executive for additional information.

A New UDI Measure Adds Another Data-Exchange Requirement

Beginning with the 2027 EHR reporting period, CMS is adding a Unique Device Identifiers for Implantable Medical Devices measure to the Public Health and Clinical Data Exchange objective. The measure brings implantable-device data into the Promoting Interoperability conversation and gives hospitals another workflow to map before reporting begins.

For IT leaders, the immediate task is not to redesign the process in isolation. It is to understand where device information is captured today, which systems support it, and which Clinical, Quality, Compliance, and technology teams need to be involved as implementation guidance is applied.

Not Every Finalized Change Belongs on the Same Timeline

The final rule also delays the removal of the Support Electronic Referral Loops by Sending Health Information and Support Electronic Referral Loops by Receiving and Reconciling Health Information measures until the 2029 EHR reporting period. Any planning based on an earlier removal date should be updated to the final timeline.

Other provisions sit at opposite ends of the planning horizon. The ONC Direct Review and ONC-Authorized Certification Body Surveillance attestations are removed beginning with the 2026 EHR reporting period. The finalized eCQM additions and removals take effect in the CY 2028 reporting period, which corresponds to the FY 2030 payment determination.

For lean hospital teams, separating immediate, near-term, and longer-range requirements is more useful than treating the final rule as one implementation project.

What Hospital IT Teams Should Review Now

A focused readiness review can turn the rule into an actionable implementation calendar. Hospital teams should be able to answer:

• Which changes affect the current reporting period, 2027, 2028, and later years?
• Which EHR, interface, API, or certified health IT dependencies are involved?
• Which requirements require coordination with Clinical, Quality, Compliance, Revenue Cycle, or external payers?
• What still needs to be confirmed with CMS, technology vendors, or other partners?
• Who owns each requirement through testing, implementation, and reporting?

The goal is not to create work before it is necessary. It is to give each requirement an owner and a realistic place on the hospital's regulatory road map before deadlines begin driving the work.

Keeping Regulatory Change Manageable

The FY 2027 IPPS final rule introduces changes on different timelines, but the practical question for hospitals is straightforward: Is your EHR ready to support what comes next?

That means understanding which requirements affect current workflows, where system or interface updates may be needed, and what should be addressed now versus what should be monitored for later implementation.

For community hospitals, readiness is not just about meeting a reporting requirement. It is about ensuring your EHR can continue to support evolving interoperability, documentation, and regulatory expectations without causing unnecessary disruption.

As requirements change, MEDHOST continues to advance its EHR to help hospitals stay prepared for the changes ahead.

Preparing for What’s Next?
Connect with MEDHOST to learn how we are supporting hospitals as regulatory and interoperability requirements continue to evolve.