Your Approach to PROMs Could Determine Your Compliance — and Your Bottom Line

Our Becker’s Healthcare webcast polling shows the confidence level attendees have in meeting CMS THA/TKA PRO-PM requirements broken down by the PROs (patient-reported outcomes) collection mechanism.

CMS is now holding hospitals accountable for collecting and reporting patient-reported outcomes (PROs) for a minimum of 50% of patients who undergo primary total hip and knee replacement. The THA/TKA PRO-PM measure is tied to a high-stakes financial consequence; 25% of the Annual Payment Update (APU) is at risk if an organization fails to meet the reporting requirements. And this reduction doesn’t just impact orthopedics — it affects all Medicare Fee-For-Service Part A claims submitted by your hospital.

During our recent Becker’s webcast, “Cracking the CODE on CMS PROs: Real-World Lessons from Health Systems,” we unofficially polled hundreds of attendees to assess confidence levels in meeting the CMS THA/TKA PRO-PM. The responses reveal an urgent need for action — particularly depending on how PROs are being collected.

Third-Party Vendors: High Confidence, High Performance

Among organizations using a third-party vendor, 56% report being very confident they will meet the measure — the highest level of confidence across all collection methods. Only 5.6% say they’re not confident at all.

This is consistent with our own client data: 95% of CODE Technology clients are on track to meet the CMS requirements. Why? CODE offers specialized implementation support, multi-channel patient engagement, and dedicated account teams who do the heavy lifting — all without disrupting clinical workflows.

• Challenge: Finding a vendor with deep PROMs experience and a proven track record.
• Benefit: Reliable capture rates, less burden on internal staff, and significantly greater confidence in compliance.

EHR-based Collection: Widespread Uncertainty

Hospitals relying on EHRs to collect PROs showed mixed results: only 33% are very confident, while over a quarter (26%) are not very confident. And more than 40% fall into the “somewhat confident” category.

While using the EHR as source of truth for all things has appeal, building a PROMs collection and reporting system within the EHR is far from turnkey. It requires significant IT resources to build and maintain, and since most EHRs lack native functionality for tracking measure performance, additional customization and support are often needed—adding to the complexity and resource burden. The webinar’s panelists, made up of PROs experts from leading systems, noted key limitations. Many lack the patient engagement tools and tracking workflows needed to achieve high capture rates. In some cases, submitting data through the EHR has even required manual entry for reporting and unexpected costs – And don’t overlook the financial consequences of missing the requirements.

• Challenge: Limited customization, lack of automation, and dependency on already-burdened clinical teams.
• Benefit: Seamless integration with existing systems (if implemented well) and centralized data.

Employed Personnel: Resource-Intensive and Risky

Health systems using internal staff to collect PROs saw the highest rate of “somewhat confident” responses (50%) — and only one-third felt very confident. The remaining 17% were either unsure or not confident.

Relying on internal teams often means inconsistent follow-up, difficulty maintaining high response rates, and vulnerability when staff are unavailable. While it may seem cost-effective upfront, the operational overhead and risk of non-compliance can far outweigh any initial savings. We often see organizations dedicate FTEs to collecting surveys—but not actually using the data. Yet the core intent of this measure is for healthcare providers to integrate PROMs into clinical decision-making, not just check a box for compliance.

In many cases we discover with new clients that, despite active PROMs collection efforts, not all required data elements are being captured. This means their data sets fall short of CMS requirements—putting compliance at risk despite significant time and resource investment.

• Challenge: Labor-intensive, subject to turnover, often incomplete data, and difficult to scale.
• Benefit: Full control over the process and data — if resourced adequately.

Other Methods: High Uncertainty and Financial Risk

Organizations falling into the “Other” category showed the lowest level of confidence. Only 12.5% reported being very confident, while 25% were not confident and 63% were only somewhat confident.

Don’t Leave Millions on the Table

Hospitals that fail to meet the THA/TKA PRO-PM requirements will lose 25% of their APU — a number that can easily reach millions of dollars. This penalty applies to all Medicare Part A claims, not just orthopedics.

Not sure how much is at stake for your organization? We can help you calculate the financial risk — and show you how to avoid it.

If you’re not very confident in your current PRO collection method, now is the time to course-correct. At CODE Technology, we specialize in helping hospitals meet CMS requirements with zero workflow interruption and industry-leading capture rates.