Get Ahead or Fall Behind: Why Orthopedic Leaders Should Jump on the CMS THA/TKA PRO-PM Voluntary Reporting Period

CMS’s mandatory patient-reported outcomes (PRO) reporting for inpatient hip and knee replacements is already in effect. Outpatient procedures are next—and smart orthopedic surgeons and their administrative leaders aren’t waiting for the deadline to get ready.

Why? The practices that prepare now will lead when it matters most.

The Smart Move? Voluntary Reporting.

If the work you do touches orthopedic lines, you’ve likely heard about the CMS THA/TKA PRO-PM (Total Hip Arthroplasty / Total Knee Arthroplasty Patient-reported Outcomes Performance Measure). While inpatient facilities are already under mandatory reporting, outpatient facilities—including hospital outpatient departments (HOPDs) and ambulatory surgery centers (ASCs)—are currently in a voluntary reporting period that runs through 2027.

This window is your opportunity to get ahead—before CMS requires outpatient participation under the Outpatient Prospective Payment System (OPPS) starting in 2028.

Understand What’s Coming for OPPS

Here’s what CMS will require for outpatient THA/TKA PRO-PM reporting beginning in 2028:

• HOPDs must report paired PROMs for at least 50% of eligible patients.
• ASCs must report paired PROMs for at least 45% of eligible patients.

Failure to meet these thresholds will result in a 2% reduction in your Annual Payment Update (APU) under the OPPS. This is a significant financial impact. 

Voluntary reporting now gives you time to build and refine a program—without financial risk.

Use the Quiet Years to Build a Flawless Workflow

The voluntary period is your proving ground. There’s no public reporting, no penalties—just the chance to:

• Set up a scalable PROMs workflow
• Identify data capture gaps and address them
• Train your team or evaluate a vendor partner
• Start measuring and using patient reported outcome data

By 2028, you’ll be ahead of the curve—while your competitors are still figuring it out.

CMS Will Give You Private Feedback

Participating voluntarily means CMS will provide you with confidential performance feedback, including capture rates and PROMs completion metrics. This gives you time to course-correct and improve before the data becomes public.

• Benchmark your progress
• Spot and solve data issues
• Build confidence in your numbers

No surprises. Just smart preparation.

Market Your Outcomes, Not Just Your Surgeons

Patients have options—and they’re doing their homework. Great outcomes are no longer a bonus; they’re a selling point.

Voluntary PROMs collection enables you to:

• Prove your value to patients and payers
• Turn outcome data into marketing assets
• Strengthen referral networks with transparent results

“We deliver better outcomes” sounds great. But when you have the data to back it up, it’s a brand advantage.

You Don’t Have to Do It Alone

Building an internal PROM program that meets CMS standards isn’t easy. That’s where CODE Technology comes in.

We’re not just software—we’re your full-service PROMs partner, managing:

• Patient outreach and engagement
• Survey delivery and follow-up
• CMS-compliant data reporting
• High-impact analytics dashboards

All with zero disruption to your staff. CODE clients consistently achieve industry-leading capture rates—well above what CMS will require in 2028.

Summary: This Is the Time to Get It Right

If you run an orthopedic practice or service line and think like a business owner, this voluntary reporting period is your opportunity to stand out. While others wait, you can prepare—and win.

• Avoid future APU penalties
• Improve your outcomes
• Strengthen your brand with data
• Go live before PROMs become public

Start now, while there’s still time to make strategic choices.

CODE Technology recommends beginning PROMs program preparation in July of the year before you plan to start participating in THA/TKA PRO-PM reporting. This timeline ensures a smooth rollout and meets CMS reporting requirements. 

Request from CODE a custom CMS Annual Payment Update (APU) financial risk estimate.