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.

CMS Compliance & PROMs Fundamentals
Yes. Systems such as Epic and other major EHR platforms can deploy validated PROM surveys through patient portals, such as MyChart, but enabling surveys and operating a sustainable PROM program are two very different challenges. EHRs do not manage the operational program required to sustain high survey capture rates or national benchmarking.
Capture rates and long-term follow-up. Most EHR workflows rely on patient portals, which often result in incomplete one-year follow-up.
The program requires both pre-operative and one-year surveys with minimum capture thresholds. Maintaining those rates requires ongoing outreach and monitoring that many EHR-based programs are not designed to support.
Many organizations use a PROM platform or managed service to handle survey distribution, follow-up outreach, benchmarking and regulatory reporting while the EHR stores the clinical data.
Patient-reported outcome measures (PROMs) are standardized surveys that capture how patients report their health status, symptoms, and quality of life after treatment. In orthopedics, commonly used PROMs include KOOS, HOOS, and PROMIS Global-10. These instruments are increasingly required for federal programs such as the CMS THA/TKA PRO-PM.
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Vendor vs. Internal vs. EHR for CMS PROMs
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.
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.
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.
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.
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Implementation & Integration
Most CODE clients are collecting within 30 days of signing, followed by a 60-day refinement period.
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.
Data reconciliation is complex. Panelists recommend consolidating on one platform early to ensure consistent reporting to CMS.
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Data Use & Strategic Value
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.
Many sites use dashboards and monthly meetings to track capture rates and improvement scores, bringing in physician champions and operational leaders.
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.
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