Guide to CMS Age Friendly Hospital Structural Measure

As of January 1, 2025, hospital quality and compliance leaders face an urgent challenge to comply with the Centers for Medicare and Medicaid Services’ (CMS) Age-Friendly Hospital Structural Measure. This measure, now a mandatory component of the fiscal year 2025 Hospital Inpatient Prospective Payment System (IPPS) final rule under the Hospital Inpatient Quality Reporting (IQR) Program, requires hospitals to demonstrate patient-centered care specifically tailored for older patients with multiple chronic conditions.

While hospitals are not required to answer “yes” to each attestation item, they are required to report whether or not these practices are in place—and those responses will be publicly posted on CMS Care Compare beginning with the 2025 reporting year. A hospital that reports “no” may still receive full IQR credit, but it risks reputational damage, scrutiny from payers and accrediting bodies, and lost ground in competitive markets.

Hospitals that fail to comply with the reporting requirements risk significant financial penalties, including reductions in Medicare reimbursement, making immediate preparation and compliance critically important. Hospitals could lose up to 29.3% of their annual Medicare payment update (see examples below), underscoring the critical need for proactive compliance.

This measure specifically applies to Medicare-participating hospitals under the IQR Program. The Age Friendly Structural Measure is built on the work of several organizations, including the American College of Surgeons (ACS), the Institute for Healthcare Improvement (IHI) and the American College of Emergency Physicians (ACEP), and is intended to mandate that hospitals demonstrate patient-centered care for patients with multiple chronic conditions.

The Rationale Behind the New CMS Age Friendly Hospital Structural Measure

The attestation-based structural measure broadens the scope of hospitals’ quality reporting efforts by moving away from narrowly defined or siloed quality reporting metrics. It introduces a wider umbrella that integrates previously separate measures into a cohesive, age-friendly framework. This framework covers key pillars such as defined healthcare goals, medication management, frailty screening, social vulnerability, and top-down, age-friendly hospital leadership.

At a time when hospitals are increasingly treating older patients with complex medical, behavioral and psychosocial needs, CMS’ Age Friendly Hospital Structural Measure is built around three core components, according to ACS, IHI, and ACEP, the organizations behind its creation:

• Following an essential set of evidence-based practices.
• Causing no harm.
• Aligning with the “4Ms” framework, which encompasses What Matters; Medication; Mentation; and Mobility.

“The elements of the ‘4 Ms’ help organize care for older adults’ wellness regardless of the number of chronic conditions, a person’s culture, or their racial, ethnic, or religious background,” CMS says.

Potential Penalties for Noncompliance with the Age Friendly Hospital Structural Measure

Hospitals that fail to comply with the Age Friendly Hospital Structural Measure face significant consequences under the CMS IQR Program. Hospitals stand to lose up to 29.3% of their Medicare payment update if they fail to meet the Age Friendly Hospital Structural Measure requirements. The American College of Surgeons, which helped develop the measure, created a post detailing the potential financial penalties below.

• Hospital A (800-bed hospital)
  • Previous Year Medicare Revenue: $383,970,642
  • Full 2.9% Update: $395,105,791 (+$11,135,149)
  • Reduced 2.05% Update: $391,842,040 (+$7,871,398)
  • Loss of approximately $3,264,000 by not meeting IQR requirements
• Hospital B (186-bed hospital)
  • Previous Year Medicare Revenue: $23,824,476
  • Full 2.9% Update: $24,515,386 (+$690,910)
  • Reduced 2.05% Update: $24,312,878 (+$488,402)
  • Loss of approximately $202,500 by not meeting IQR requirements
• Hospital C (25-bed hospital)
  • Previous Year Medicare Revenue: $2,686,037
  • Full 2.9% Update: $2,763,932 (+$77,895)
  • Reduced 2.05% Update: $2,741,100 (+$55,064)
  • Loss of approximately $22,830 by not meeting IQR requirements

In addition to financial penalties, hospitals that fail to meet the measure will be publicly reported as noncompliant on the CMS Care Compare website. This transparency can influence patient choices, damage the hospital’s reputation, and impact its competitiveness in the healthcare market. Furthermore, noncompliance may raise concerns with accrediting bodies and third-party payers.

To avoid these consequences, hospitals must prioritize timely and accurate reporting of the Age Friendly Hospital Structural Measure using the Hospital Quality Reporting (HQR) system. Proactive engagement with leadership, staff training, and the implementation of evidence-based protocols are essential to ensuring compliance.

Detailed Breakdown of the Five Age Friendly Structural Measure Domains

Domain 1: Eliciting Patient Healthcare Goals

This domain focuses on obtaining a patient’s health-related goals and treatment preferences which will inform shared decision making and care aligned with patient goals.

Domain 2: Responsible Medication Management

This domain aims to optimize medication management through monitoring of the medication record for drugs that may be considered inappropriate in older adults due to increased risk of harm.

Domain 3: Frailty Screening and Intervention

This domain aims to screen patients for common age-related issues like frailty, including cognitive impairment/delirium, physical function/mobility, and malnutrition for the purpose of early detection and intervention where appropriate.

Domain 4: Social Vulnerability

This domain seeks to ensure that hospitals recognize the importance of social vulnerability screening of older adults and have systems in place to ensure that social issues are identified and addressed as part of the care plan.

Domain 5: Age-Friendly Care Leadership

This domain seeks to ensure consistent quality of care for older adults through the identification of an age-friendly champion, typically a clinical leader or administrative figure, and/or interprofessional committee tasked with ensuring compliance with all components of this measure.

CMS Age Friendly Hospital Measure Reporting Requirements and Timeline

The CMS Age Friendly Hospital Measure offers a total of five possible points, with one point awarded for each of the domains successfully attested to. The hospital or health system determines whether it performed each of the elements that comprise the domain.

CMS does not allow partial points. For successful attestation, hospitals and health systems must affirmatively attest to each statement within a domain. For example, in Domain 3, if a hospital attests to statements A, C and D – but not statement B – then the hospital would not receive a point for the domain.

However, CMS has confirmed that hospitals will receive full IQR credit simply for submitting their attestation, regardless of whether the answers are “yes” or “no.” This makes the measure pay-for-reporting, not performance-based—at least for now.

However, attestation responses will be publicly reported on CMS Care Compare beginning with the 2025 reporting year. This means that even if hospitals receive IQR credit for reporting, their “no” responses will be visible to patients, payers, and accrediting bodies—creating reputational and strategic risk.

The first reporting year for the measure is calendar year 2025. The payment determination year for 2025 results is calendar year 2027. To report, hospitals must submit information for the Age Friendly Hospital Measure once per year using a CMS-approved web-based data collection tool specifically designated for the IQR program as part of the Hospital Quality Reporting (HQR) system.

CMS Age Friendly Hospital Measure Implications for Hospitals and Healthcare Leaders

The Age Friendly Measure assesses a hospital’s commitment to improving care for older patients with chronic conditions with a focus on patient goals, medication management, frailty, social vulnerability and leadership. Aligning goals and operations with the Age Friendly Measure requires:

• Strength in Leadership: One of the five domains of the Age Friendly Hospital Measure specifically focuses on leadership. The domain calls for a “champion” and/or an “interprofessional committee” to bring focus and lead the way on the multiple attestation goals.
• Knowledge of the Details: Hospital staff must have ready knowledge of the multiple domains that comprise the Age Friendly Hospital Measure. Full domain and attestation details are available in the Federal Register and within other resources, such as QualityNet.
• Create a Path for Success: Leaders must identify which domains and attestations the hospital may already cover and conduct a gap analysis on the domains that it can successfully attest to.

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