The Top FAQs About CMS Patient-Reported Outcome Measures (PROMs)

Apr 25, 2025

Your Most Pressing PROMs Questions — Answered by CODE and Hospital Leaders Tackling CMS PROM Compliance, Capture Rates, and Data Utilization

Patient-reported outcome measures (PROMs) are playing a critical role in today’s healthcare landscape — especially with the introduction of CMS’s THA/TKA PRO-PM. Failure to meet the 50% capture rate can result in a 25% reduction in the Annual Payment Update (APU) across all inpatient Medicare Part A claims — a penalty that can reach millions of dollars.

To help hospitals navigate these challenges, CODE Technology hosted a webcast, Crack the CODE on CMS PROs: Real-World Lessons from Health Systems, where leaders shared their experiences managing PROMs and meeting CMS requirements. This article recaps the top questions asked by attendees with real-world answers and strategic takeaways.

Hospital manager talking to a doctor and looking at a medical record

CMS Compliance & PROMs Fundamentals

What is the average post-operative response rate for PROs collection?

CODE clients average 80% post-op response rates. 95% are on track to meet the CMS threshold.

What outreach methods are used for PROMs?

Successful programs use a mix of email, phone, and SMS to maximize response rates.

Who is included in the denominator for THA/TKA PRO-PM?

Medicare FFS patients age 65+ undergoing elective, primary hip or knee replacements — regardless of whether Medicare is the primary, secondary, or tertiary payer.

What’s the difference between the AAOS Registry and CODE’s platform?

American Academy of Orthopedic Surgeons (AAOS) offers a national registry. CODE is an AAOS-preferred PROMs vendor and a CMS-approved QCDR (Qualified Clinical Data Registry) that collects and reports clinical data for hospitals and private practices. CODE offers a robust platform for collection, reporting, and analytics — all with managed services support and zero workflow disruption. CODE has also built a robust registry for client benchmarking – 10 years and counting.

Vendor vs. Internal vs. EHR for CMS PROMs

Why do organizations switch from using internal FTEs to a third-party vendor for PROMs management?

Typically, internal models are not scalable. One panelist shared that after a cost-benefit analysis, outsourcing was not only more efficient but also enabled more robust use of the data — not just collection. Another key challenge: post-operative PROMs are often collected after the patient has left the hospital, making follow-up difficult for in-house teams. Third-party vendors bring multi-channel tools and dedicated workflows that help close this gap and ensure higher response rates beyond discharge.

Why implement a system-wide PROMs platform?

Rather than letting each site build its own solution, one panelist shared that the organization standardized on a single platform across nearly 100 hospitals. This approach improved consistency, visibility, and performance benchmarking.

What are the limitations of using the EHR to manage PROMs?

While EHRs may seem like a convenient option, real-world results reveal significant limitations. Survey fatigue, inconsistent provider adoption, and a lack of built-in accountability often lead to poor follow-up — one panelist reported a 0% post-op completion rate despite strong pre-op engagement.

Beyond workflow challenges, EHR-based PROM programs face major hurdles in implementation, cost, and scalability:

Implementation timelines can stretch 12–24 months
Hidden costs pile up
Capture rates are often low
Data extraction is labor-intensive

These limitations underscore why many hospitals turn to third-party vendors that deliver faster onboarding, higher capture rates, and easier compliance reporting. Read more on risks of using an EHR to collect PROs.

When should a hospital consider switching PROMs strategies?

If reporting is difficult, capture rates are low, or staff resources are strained, it’s a sign that your current approach isn’t sustainable — and it may already be putting your CMS compliance at risk. Another red flag: if you can’t track your organization’s performance against specific PRO-PM criteria within the EHR.

Many hospitals that delayed switching vendors regretted not making the move before the CMS performance year began. The good news? With CODE Technology, we can pick up right where your collections left off — even mid-year — helping you meet reporting requirements without starting over.

Implementation & Integration

How long does it take to go live with a PROs program with CODE?

Most CODE clients are collecting within 30 days of signing, followed by a 60-day refinement period.

What are common implementation challenges with PROMs programs?

Standardizing procedure codes, inconsistent surgery scheduling, and missing patient contact information are among the top challenges. Even the most prepared teams often underestimate how time-consuming integration can be — particularly when foundational workflows aren’t aligned.

As one panelist put it, “It’s always the journey of standardization, right? And I think the surgery scheduling workflow really is the most important one because you have to get that accurate, complete patient contact information captured as early on as possible… If I had to start one place, it would be with those scheduling workflows for sure.”

Starting early and prioritizing clean, consistent scheduling processes is critical to ensure timely pre-op outreach and downstream success with PROs collection.

What happens if you use two PROM systems in one performance year?

Data reconciliation is complex. Panelists recommend consolidating on one platform early to ensure consistent reporting to CMS.

Data Use & Strategic Value

How is patient-reported outcome measures (PROMs) data being used beyond CMS compliance?

Panelists shared a few ways they are utilizing the PROMs data:

Robotic surgery justification: One system found significantly better PROM scores among robotic procedures, leading to expanded investment.
Patient education: Several teams used free-text survey responses to refine pre-op education and improve discharge outcomes.
Co-management: PROMs supported quality alignment with affiliated physicians and informed decisions about implants and clinical pathways.

How is PROM performance shared internally?

Many sites use dashboards and monthly meetings to track capture rates and improvement scores, bringing in physician champions and operational leaders.

What’s the role of PROMs in the future of value-based care?

PROMs are becoming the currency of value-based care. CMS is rolling out more PRO-PMs, and commercial payers are following. Health systems need long-term infrastructure for digital, scalable outcomes reporting.

Do you have additional questions not answered here?

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