CMS Releases Technical Guidance For QRS And QHP Enrollee Experience Surveys

Implementing Health Reform. In late September 2015, the Centers for Medicare and Medicaid Services (CMS) released its Quality Rating System (QRS) and Quality Health Plan (QHP) Enrollee Experience Survey: Technical Guidance for 2016 as well as its 2016 QRS Measure Technical Specifications.

The Affordable Care Act (ACA) requires the Department of Health and Human Services (HHS) to develop a quality rating system and enrollee satisfaction survey program for qualified health plans. Based on this authority, CMS issued a regulation in 2014 that established standards and requirements for QHP issuer data collection and public reporting of quality and satisfaction rating information. In the fall of 2014, CMS released a technical guidance establishing a beta test of a QRS and enrollee satisfaction survey system to be conducted during 2015.

The 2016 Technical Guidance sets out the framework for the actual collection of QRS and enrollees satisfaction survey data during 2016 for display on marketplace websites and in QHP marketing material for the 2017 open enrollment period. QHP issuers with more than 500 enrollees in a particular product type (EPO, HMO, PPO, or POS) must submit validated enrollee satisfaction survey data for each product type, collected by an HHS-approved QHP enrollee survey vendor by May 25, 2016 and validated QRS clinical measure data by June 15, 2016. QHP issuers must submit data for 43 QRS measures (described in detail in the Technical Specifications document).

As in 2015, however, only 28 of the measures will actually be used for scoring (29 measures were collected in 2015). Scores will be calculated according to a process set out in the Guidance for compiling star ratings for plans, which will be displayed on the marketplace websites and can be used by plans for marketing (subject to restrictions and disclaimers set out in the guidance.)

HHS has not yet completed analysis of the 2015 Beta test. The guidance notes that a revised version of the 2016 technical guidance containing refinements in the rating methodology and additional information regarding the preview and display of rating information will be issued once analysis of the 2015 Beta test is completed.

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