Quality Improvement Strategy FAQs

Q1: Should an issuer password protect or scan its Quality Improvement Strategy (QIS) Implementation Plan and Progress Report form prior to submission?

  • No. Issuers should not password protect or scan their QIS Implementation Plan and Progress Report forms prior to submission via the Health Insurance Oversight System (HIOS) or the System for Electronic Rate and Form Filing (SERFF). Issuers should submit their QIS forms as fillable-PDF files, as opposed to files that have been scanned. Password protecting and/or scanning QIS submissions prevents the Centers for Medicare & Medicaid Services (CMS) from processing QIS submissions for evaluation. Issuers who submit scanned and/or password protected QIS Implementation Plan and Progress Report forms will be asked to reformat and/or remove password protection and resubmit.

Q2: How does an issuer applying for Qualified Health Plan (QHP) Certification in the Federally-facilitated Exchanges (FFEs) for the upcoming plan year demonstrate compliance with QIS?

  • As specified in 45 C.F.R. §156.1130(c), issuers participating in an Exchange for two or more consecutive years must implement and report on a QIS in a manner and timeframe specified by the Exchange. This includes providing annual updates on their existing quality improvement strategies.

    Issuers participating in the FFEs that submitted a QIS Implementation Plan for a prior plan year are required to submit a QIS Progress Report on their quality improvement strategies for the upcoming plan year.

NOTE: For the 2020 Plan Year, requirements for reporting QIS progress have changed based on minimum enrollment thresholds.For more information, see Question 3, below, as well as page 17 in the QIS Technical Guidance and User Guide for the 2020 Plan Year (QIS Guidance), available on the MQI website.

Additional details on the QIS submission requirements, participation criteria, and timeline can also be found in the QIS Guidance.

At this time, issuers participating in the FFEs will not be penalized for failure to meet their performance targets. However, each issuer should strive to achieve progress toward meeting the goals and corresponding performance targets specified in its QIS. Issuers will also not be penalized if they need to adjust the timelines or redefine the milestones in an existing QIS.

Q3: How often will an issuer’s minimum enrollment threshold be calculated?

  • Starting in the 2020 Plan Year, CMS will assess an issuer’s product type enrollment after two consecutive QIS Progress Report submissions. Issuers must provide two consecutive years of progress updates if they are continuing their QIS, regardless of whether these issuers’ product type(s) meet the minimum enrollment threshold, as shown in the table below. Issuers may discontinue progress reporting if their product type(s) no longer meet the minimum enrollment threshold prior to the third consecutive year of progress reporting.

Calendar Year of Implementation Plan Submission

Implementation Plan (Plan Year)

Progress Report (Plan Years)

Calendar Year of Minimum Enrollment Reassessment

Progress Report (Plan Years), if Minimum Enrollment Threshold Met

2016

2017

2018 and 2019

2019

2020 and 2021

2017

2018

2019 and 2020

2020

2021 and 2022

2018

2019

2020 and 2021

2021

2022 and 2023

2019

2020

2021 and 2022

2022

2023 and 2024

2020

2021

2022 and 2023

2023

2024 and 2025


Q4: What is the QIS evaluation timeline and process?

  • CMS will evaluate QIS submissions according to the timeline for QHP Certification in the FFEs described in the annual Letter to Issuers. Per the current QHP Certification timeline, there are two review periods during the QHP Application submission and review period (QHP Application Period), during which the FFEs, including FFEs where States perform plan management, evaluate issuers’ QIS submissions.

    QIS submissions received during the QHP Application Period will be assessed for completeness. Issuers whose submissions contain blank fields or are missing information will receive correction notices after the first round of QHP Application review indicating which fields were missing information. Issuers that receive correction notices identifying QIS deficiencies must correct and resubmit their QIS Implementation Plan and Progress Report forms during the subsequent review period. Issuers whose resubmissions contain missing info or blank fields after the second round of review will not receive second correction notices but will be notified of potential concerns during the Post-Certification Assessment (PCA) period.

    Issuers that met the QIS participation criteria, but did not submit at least one QIS as expected, will receive a correction notice after the first round of review.  If they do not submit a QIS form during the subsequent review period, they will receive a second correction notice.

    Issuers will not be notified if their QIS submissions are assessed as complete during the QHP Application period. Issuers will not be notified if their QIS submissions receive an overall outcome of “Meets” during the PCA period.

Q5: How should an issuer respond to Element 16 in the QIS Implementation Plan and Progress Report form if its percentage of any payment model is greater than 0%, but less than 1%?

Q6: Does an issuer need to submit a separate QIS for each eligible product type (e.g. Health Maintenance Organizations (HMOs), Preferred Provider Organizations (PPOs), Point of Service (POS) plans, Exclusive Provider Organizations (EPOs), and indemnity plans) within an Exchange?

  • No. An issuer may choose to implement a single QIS to cover all of its eligible health plans and product types or may choose to implement multiple quality improvement strategies.

Q7: Can the QIS Implementation Plan and Progress Report form be submitted independently of the larger QHP Application?

  • Issuers should submit their QIS Implementation Plan and Progress Report forms as part of QHP Certification, when they submit their QHP Applications. Submission instructions related to the QHP Application and QIS Implementation Plan and Progress Report form may vary by Exchange. For example, issuers operating in FFE States will submit via HIOS. For the 2020 Plan Year, the QIS Implementation Plan and Progress Report form will be submitted through the Accreditation Module. Issuers operating in FFEs where States perform plan management will submit via SERFF. Issuers operating in State-based Exchanges (SBEs) or SBEs on the Federal Platform (SBE-FPs) should contact their Exchange for specific instructions on QHP Application submission, including QIS submission.

Q8: Should an issuer use its Quality Rating System (QRS) survey results as its QIS baseline data in Element 24 of the QIS Implementation Plan and Progress Report form?

  • Issuers are not required to use QRS survey results for their QIS baseline data. Issuers may choose to use QRS survey results or may choose to use other data sources that identify QHP enrollee population needs and support their QIS rationale for their QIS baseline data in Element 24 of the QIS Implementation Plan and Progress Report form.

Q9: What is QIS baseline data?

  • Baseline assessment results should measure an issuer’s performance before beginning the QIS and serve as a basis for comparison with results for the same measure in subsequent years. When reporting on progress, issuers should use the data from their initial QIS Implementation Plan if they have not modified their measures. 

Q10: What is the due date for QIS Implementation Plan and Progress Report form submission?

  • The QIS Implementation Plan and Progress Report form must be submitted during the QHP Application submission and review period. The CMS timeline can be found in the 2020 Letter to Issuers in the Federally-facilitated Exchanges.

Q11: For issuers in FFE States, including FFEs where States perform plan management, what happens to issuers' QIS Implementation Plan and Progress Report forms following submission during QHP Certification?

  • For issuers in FFE States, including FFEs where States perform plan management, QIS forms submitted during QHP Certification are first assessed for completeness, and then undergo full evaluation by CMS.

    Issuers participating in the FFEs whose QIS forms were not received as required, were missing information, or contained blank fields receive correction notices during QHP Certification that specify any QIS deficiencies. Issuers participating in the FFEs that receive correction notices must correct and resubmit their QIS forms.

    If issuers participating in the FFEs do not receive correction notices that list QIS deficiencies, their QIS forms are complete and will undergo full evaluation.

    For issuers in FFEs where States perform plan management, the submission is jointly reviewed by CMS and the State, with the final determination being made by CMS. Issuers operating in these States should contact the State for details on the State's process for evaluating QIS submissions.

Q12: When will CMS notify issuers operating in FFE States, including FFEs where States perform plan management, of their full QIS evaluation results?

  • CMS notifies issuers in FFE States, including FFEs where States perform plan management, of any concerns with their QIS submissions based on their full QIS evaluation results at the end of the calendar year during the PCA Period, which occurs after the conclusion of the annual QHP Certification Period in which the QIS submissions were made. For example, issuers participating in the FFEs will receive a notice of potential concerns at the end of calendar year 2019 for QIS submissions made during 2020 QHP Certification.

    An issuer participating in an FFE that receives outreach regarding potential concerns with its QIS must work with CMS to address these concerns.

    CMS does not provide affirmative notification of fulfillment of the QIS requirements. Issuers participating in the FFEs that do not receive notification of potential concerns by the end of the calendar year following the conclusion of the applicable QHP Certification cycle should continue their QIS implementation.

    For issuers in FFEs where States perform plan management, the submission is jointly reviewed by CMS and the State, with the final determination being made by CMS. Issuers operating in these states should contact the State for details on the State's process for evaluating QIS submissions.