MIPS Quality Measures for Heart Failure: A Provider’s Guide to CMS90 / MIPS #377

Reporting requirements, eligible PROMs, submission timelines, and what the Ambulatory Specialty Model means for your practice

If you treat heart failure patients, MIPS quality measures are already part of your reporting landscape, and one of them is becoming significantly more important. CMS90 (MIPS Quality Measure #377) requires eligible providers to document both an initial and follow-up functional status assessment for adult heart failure patients using a validated patient-reported outcome measurement (PROM) tool. Many cardiology and heart failure programs have been doing this kind of monitoring for years. CMS has now formalized these workflows within quality reporting and payment programs and finalized the Ambulatory Specialty Model (ASM), a mandatory specialty-focused payment model scheduled to begin in 2027 for eligible providers in selected geographic regions.

This guide covers what the measure requires, how to meet it, which PROM tools qualify, and what the ASM means for practices in affected regions.

What Are MIPS Quality Measures for Heart Failure? Understanding CMS90 / MIPS #377

CMS90, also known as MIPS Quality Measure #377, is a patient-reported outcome process measure. In plain terms: it tracks whether adult heart failure patients complete a validated functional status questionnaire at two points in time: once near an initial encounter and again 30 to 180 days later.

The measure is not assessing how sick your patients are or whether their condition improved. It’s a process measure — meaning CMS is asking whether you collected the data, not what the data showed. That distinction matters operationally, because the path to a high score is workflow compliance, not clinical outcomes.

Measure ID	CMS90v15 / MIPS Quality ID #377
Measure type	Process — patient-based eCQM
Performance year	2026 (CMS90v15); annual updates apply
Steward	Centers for Medicare & Medicaid Services (CMS)
Scoring	Proportion measure: Higher performance = Higher score
Risk adjustment	Not applicable to this process measure
Reporting path	EHR-based eCQM reporting under traditional MIPS and applicable MVP pathways

A Brief History: How This MIPS Quality Measure Evolved

CMS90 has been in the clinician eCQM set since at least 2017, with published specification updates each year through the CMS Quality Payment Program (QPP). The measure has quietly matured from a niche quality reporting option into something that now carries real payment implications — particularly for specialists.

The fact that it’s been around since 2017 and is now being incorporated into a mandatory payment model tells you something: CMS views longitudinal functional status data as foundational to how it will evaluate heart failure care going forward. If your program isn’t collecting it yet, now is the time to build that workflow.

Why MIPS #377 Is Getting More Important: The Ambulatory Specialty Model

Eligible cardiology specialists in selected geographic regions who meet CMS episode volume thresholds will be required to participate. Medicare Part B payments will be adjusted up or down based on performance across quality, cost, and interoperability measures.

Functional Status Assessments for Heart Failure (MIPS Q377) is included in the ASM quality performance category for heart failure participants. That means the functional status assessment workflows you build today are not just about MIPS reporting — they’re the foundation for how your practice performs financially under a mandatory CMS model starting in 2027.

CMS90 Reporting Timeline and Submission Requirements

Data collection runs the full performance year — January 1 through December 31. Submission occurs during the QPP submission window in Q1 of the following year, historically closing around March 31 (CMS occasionally extends this deadline).

Performance year	January 1 – December 31, 2026
Submission window	Q1 2027 (historically closing ~March 31)
Submission method	EHR-based eCQM reporting via QPP portal
Data completeness	Full-year data collection required

CMS90 Measure Requirements: Denominator, Numerator and Eligible PROMs

Who’s in the Denominator

The denominator includes adult heart failure patients with sufficient engagement in your practice during the performance year. Specifically:

• Age 18 or older with a confirmed heart failure diagnosis
• At least two outpatient encounters during the performance year

Two categories are explicitly excluded:

• Patients with severe cognitive impairment
• Patients enrolled in hospice at any point during the year

Telehealth encounters are eligible — a meaningful detail for practices with significant virtual visit volumes.

What Hits the Numerator

To count a patient in the numerator, you must document both of the following in the EHR:

• Initial functional status assessment — completed within two weeks before or during an eligible encounter
• Follow-up functional status assessment — completed 30 to 180 days after the initial assessment

Critically, the same validated instrument must be used at both time points. You cannot mix tools (e.g., KCCQ for the initial and PROMIS-10 for the follow-up). In practice, the 30–180 day follow-up window is where most programs struggle — it’s wide enough to be manageable but requires active tracking to ensure completion before the window closes.

Accepted PROM Tools for CMS90

CMS90 accepts five validated instruments. The right choice for your program depends on your patient population and workflow:

KCCQ / KCCQ-12	Kansas City Cardiomyopathy Questionnaire — heart failure-specific; widely used in cardiology; strong clinical validation
MLHFQ	Minnesota Living with Heart Failure Questionnaire — heart failure-specific; well-established in both clinical and research settings
VR-12 / VR-36	Veterans RAND instruments — general health status measures; broader scope than HF-specific tools
PROMIS-10 Global	General health status measure from NIH PROMIS framework — brief 10-item version
PROMIS-29	Expanded PROMIS general health profile — covers eight health domains

Note: KCCQ and MLHFQ are heart failure-specific and generally preferred for clinical utility in HF populations. PROMIS and VR tools measure general health status — they satisfy the measure but provide less condition-specific insight. ACC/AHA/HFSA guidelines explicitly recommend KCCQ and MLHFQ for routine heart failure care.

Why CMS Is Prioritizing Patient-Reported Outcomes in Heart Failure

The clinical rationale behind this MIPS quality measure is well-established. ACC, AHA, and HFSA guidelines have long emphasized routine collection of patient-reported health status data in heart failure management — not because it’s a CMS requirement, but because it improves care.

Validated PRO tools like the KCCQ and MLHFQ give clinicians something that lab values and imaging cannot: a standardized picture of how the patient actually feels and functions. That information helps identify functional decline earlier, guide treatment decisions, flag patients who need closer monitoring, and support shared decision-making conversations that are increasingly important in value-based care models.

Practical Strategies for Improving CMS90 Performance

1. Standardize One PROM Tool Across Your Workflows

The “same instrument” requirement makes tool selection a one-time decision with long-term consequences. Choose based on your patient population and EHR integration capabilities, then standardize across intake, follow-up, and longitudinal management workflows. Switching tools mid-year means starting the numerator clock over for those patients.

For most heart failure programs, KCCQ-12 is the practical choice — it’s brief, HF-specific, and has strong EHR integration support across major platforms.

2. Automate the Assessment Windows

Manual tracking of the 30–180 day follow-up window does not scale. The most successful programs build automation into their workflows:

• Trigger initial FSA at patient check-in or 24–48 hours pre-visit via patient portal or SMS
• Auto-schedule the follow-up assessment at day +30 with reminders through the window
• Set alert thresholds so staff are notified before the day-180 window closes

The goal is to make collection automatic enough that staff intervention is only needed for exceptions — not as the primary tracking mechanism.

3. Make Telehealth a Primary Collection Channel

Because telehealth encounters are eligible under CMS90, virtual visits are not a gap in your workflow — they’re an opportunity. Build a protocol for administering FSAs during virtual visits, including a backup path for patients who need paper or phone-based completion.

4. Build a Follow-Up Management Process

High numerator rates require active follow-up management, not passive waiting. The practices that will perform well on this measure typically have:

• A due/overdue patient list reviewed regularly by care coordinators
• Re-engagement workflows for patients who miss their follow-up window
• Clean exclusion documentation for hospice enrollment and cognitive impairment — undocumented exclusions hurt your denominator and your score

The operational complexity here is real. On paper, the measure looks like a simple two-touchpoint process. In practice, sustaining high completion rates across a chronic disease population — with all its churn, no-shows, and care transitions — requires dedicated infrastructure.

How CODE Technology Can Help

CODE Technology’s end-to-end managed PROMs service is built to support exactly the kind of longitudinal patient-reported outcome workflows that CMS90 requires — from validated PROM administration and automated follow-up scheduling to EHR integration and numerator tracking. If you’re building or optimizing your FSA workflow for the 2025 performance year, our team can help you get there.

Frequently Asked Questions:
MIPS Quality Measures for Heart Failure (CMS90 / MIPS #377)

Sources: eCQI Resource Center (CMS90v16 specification) — ecqi.healthit.gov/ecqm/ec/2025/cms0090v16  |  CMS Quality Payment Program — qpp.cms.gov  |  ACC/AHA/HFSA Heart Failure Guidelines