Crosswalk document - 60/30 day compare

Revisions Crosswalk (Form CMS-10540): OMB _________ (05/27/2015)
Issue
#
1.

Page #

Section

Action to be
performed
Adjust section
and element
numbers
Combine
forms into a
single form

Changes to the Template

Reason for the Change



Adjusted so that contents are
labelled sequentially.

All

All

2.

All

All

3.

1

Part A - New or
Continuing QIS
Submission

Add new Part



4.

2

Add
instructional
clarification




5.

2

Background
Information
Part B – Issuer
Information
Part B – Issuer
Information




6.

2

Part B – Issuer
Information, Element
#14

Add
descriptions to
element names
Add new
element

7.

2

Part B – Issuer
Information, Element
#15

Move element
to different
section







Adjust section numbers/letters and element
numbers to be sequential after the addition and
replacement of previous sections and elements.
Combine two forms into a single form

Add Part A (to indicate whether issuer is
submitting a New QIS, a New QIS After
Discontinuing a QIS Submitted During the Most
Recent QHP Application Period, a Continuing a
QIS with No Modifications, or a Continuing a QIS
with Modifications)
Add header “Background Information”
Add explanation that the fields in Part B are
required, but will not be scored as part of the QIS
evaluation.
Add “Issuer” in front of State
Add “QHP” in front of other issuer information for
elements 2-13
Add element #14 “Date Issuer Began Offering
Coverage Through the Marketplace”

Move element #15 “Current Payment Model(s)
Description” from former Part D to new Part B.

Consolidated to reduce the
collection of duplicative
information based on technical
expert panel recommendations
Added because it is necessary to
collect this information so that
issuers know which parts of the
form to complete.
Added to clarify that this section is
for background information and
issuers must complete the section
but it will not be scored.
Added to clarify specific
information to be provided.
Added because it is necessary to
collect this information; only
issuers that have been operating
on the Marketplace for two
consecutive years are required to
comply with the QIS certification
standard.
Moved this element to previous
section for clarity.

Page 1 of 12

Issue
#
8.

Page #

Section
Part C – Data Sources
Used for Problem
Identification and
Monitoring Progress

Action to be
performed
Add new Part

Changes to the Template

Reason for the Change



Added to understand what data
issuers are using to inform their
QIS rationale. This section will
not be scored.

9.

3

QIS Implementation
Plan Section

Add section
header and
instructions



10.

3

Part D – QIS
Summary

Revise section
title




Add “Part C. Data Sources Used for Problem
Identification and Monitoring Progress” (with
explanation that the field is required, but will not
be scored as part of the QIS evaluation)
Add element #16 “Data Sources” with instructions
and list of potential data sources
Add section header “QIS Implementation Plan
Section” and instructions for issuers to retain a
copy of completed QIS Implementation Plan for
future use
Delete “Part B. Strategy Description”
Replace with “Part D. QIS Summary”

11.

All

All

Revise
language




Delete “Strategy”
Replace with “QIS”

12.

3

Element #17 – QIS
Title

Increase
character limit

Change character limit from 50 to 100

2-3



Added to distinguish the
upcoming section and remind
issuers to retain copies of their
submissions.
Renamed section title and adjusted
alphanumeric label based on
addition of previous sections.
Replaced to consistently use
“QIS” acronym in place of
spelling out the words “strategy”
or “quality improvement strategy”
Increased character limit to allow
issuers more flexibility for the title
of their QIS.

Page 2 of 12

Issue
#
13.

14.

Page #

Section

3

Element #18 – QIS
Description

3

Element #18

Action to be
performed
Revise
instructions

Increase
character limit

Changes to the Template

Reason for the Change



Revised instructions for added
clarity. (Editorial, non-substantive
changes.). Removed some
information to reduce
redundancies.

Delete: “Provide a brief description of the quality
improvement strategy. The description must
include:
o Market-based incentive strategy type (see item
14 below)
o QIS topic area (see item 15 below)
o Overall goal of the strategy
o If the strategy is new/not yet implement; or if it
is an existing strategy that the QHP issuer
currently has in place”
 Replace with: “Provide a brief summary
description of the QIS. The description must
include information about all of the following:
o Market-based incentive type(s) (see Element
19);
o QIS topic area(s) (see Element 20); and
o The overall goal(s) of the QIS (no more than
two), which should be labeled Goal 1 and Goal
2 (Note: Measures described in Element 24
should be linked to these goals).
o Indicate if this is a strategy that the issuer
currently has in place for its Marketplace
product line and/or for other product lines.
o Indicate if this strategy is a part of a broader
initiative at the state or regional level.
o If the strategy is part of a state initiative, check
“yes” or “no” to indicate whether participation
in the initiative is mandatory.”
 Change character limit from 500 to 1,000

Increased character limit to allow
issuers more flexibility for the
description of their QIS

Page 3 of 12

Issue
#
15.

16.

Page #

Section

4

Part E. QIS
Requirements

4

Element #19 Market-Based
Incentive Type(s)

Action to be
performed
Add clarifying
instructions

Revise
instructions

Changes to the Template






17.

4

Element #20 – Topic
Area Selection

Revise
instructions









Add “These fields will be scored as part of the
QIS evaluation. Elements marked “must pass” are
elements that must receive a “meets” score during
the QIS evaluation. If any “must pass” elements
are scored as “does not meet” in the QIS
evaluation, the issuer must revise its
Implementation Plan and submit it for re-review.”
Delete “Check at least one market-based
incentive type (provider or enrollee) and sub type
the strategy will, or already includes, in the
strategy. If “other” is selected, briefly describe the
type in the space provided. (check all that apply)”
Replace with “Check the type of market-based
incentive(s) that are used by the QIS. (Check all
that apply.) For each market-based incentive type,
check the sub-type the QIS includes. (Check all
that apply.) If “Other” is selected, briefly describe
the market-based incentive sub-type in the space
provided.”
Add “Must Pass”
Add “Market-based” in front of “incentives”
Delete “Check the box for reducing health and
health care disparities along with an additional
topic area to focus the strategy, as defined in the
Affordable Care Act.(check all that apply)
Replace with “Check box(es) for the topic area(s)
this QIS addresses, as defined in the Affordable
Care Act. (Check all that apply.) *Implementation
of activities to reduce health and health care
disparities is required. It can be selected as a
Topic Area or integrated into relevant Activities
(see 23c).”
Add “Must Pass”

Reason for the Change
Added instructions to explain that
this section contains the fields that
will be scored for QIS evaluation
and a high level summary of the
scoring process.

Revised instructions to clarify
what information issuers must
submit for this element. (Editorial,
non-substantive changes.)

Revised instructions to clarify
what information issuers must
submit for this element. Clarified
that health and health care
disparities can be addressed
through a different topic area and
does not need to be selected
individually. (Editorial, nonsubstantive changes.)

Page 4 of 12

Issue
#
18.

Page #
4-5

Section
Element #20 – Topic
Area Selection

Action to be
performed
Revise
checklist

Changes to the Template




19.

5

Part E – QIS
Requirements

20.

5

Element #21 Targets
all Health Plans
Offered Through the
Marketplace (Must
Pass)

Delete former
Element #17 –
Reducing
Health and
Health Care
Disparities
Revise
element name
and
instructions






Reason for the Change

Delete:
[ ] Reduce health and health care disparities
(required)
[ ] Improve health outcomes
[ ] Reduce readmissions
[ ] Improve patient safety
[ ] Implement wellness and health promotion
activities
Replace with:
[ ] Implementation of activities for improving
health outcomes
[ ] Implementation of activities to prevent
hospital readmissions
[ ] Implementation of activities to improve
patient safety and reduce medical errors
[ ] Implementation of wellness and health
promotion activities
[ ] Implementation of activities to reduce health
and health care disparities (if this topic area is not
selected, describe how your implementation
activities relate to health and health care
disparities in 23c.)
Delete former Element #17 – Reducing Health
and Health Care Disparities

Revised checklist language to
match the legislative language and
clarify what information issuers
must submit for this element.
(Editorial, non-substantive
changes.)

Delete QHPs
Replace with Health Plans

Replaced QHP with Health Plans
to clarify that QIS submissions
will apply to plans not yet certified
as QHPs.

Deleted this element because it is
now covered by new Element #20
– Topic Area Selection

Page 5 of 12

Issue
#
21.

Page #
5

Section
Element #21 Targets
all Health Plans
Offered Through the
Marketplace (Must
Pass)

Action to be
performed
Revise
instructions

Changes to the Template





22.

5-6

Element #21 Targets
all Health Plans
Offered Through the
Marketplace (Must
Pass)

Revise
checklist
language




Add “Must Pass”
Delete “Check “yes” if all QHPs are covered in
the strategy proposed in this template. Check
“no” if the strategy covers a subset of all the QHP
issuer’s QHPs. In the space provided, specify the
Standard Component IDs (SCIDs) for all QHPs to
which the strategy applies. Each QHP has a
unique SCID. Check the appropriate boxes to
indicate the relevant product types and categories
of coverage for which the strategy applies and
that correspond to the Standard Component IDs.
(check all that apply)”
Replace with “21a - Check “All health plans” if
the QIS applies to all health plans included in the
current QHP Application and Certification
process. Check “Subset of health plans” if the
QIS covers a subset of the issuer’s health plans.*
*Additional QIS Implementation Plan(s) must be
submitted for health plans not covered by this
QIS. 21b – Indicate the relevant product types to
which the QIS applies. (Check all that apply.) 21c
– In the space provided, specify all health plans
covered by the QIS by listing each Plan’s 14-digit
unique HIOS Plan ID (Standard Component ID
[SCID]). Indicate if each one is a new or existing
health plan.”
Revise checklist to spell out acronyms for product
types and provide clearer direction on the
information being requested
Add the collection of HIOS plan IDs (SCIDs) and
indication of “new” or “existing” health plans for
each health plan that issuer is submitting QIS for

Reason for the Change
Revised instructions to provide
more detail around the submission
of information for this element
and how issuers must indicate
which QIS submissions apply to
which health plans it offers.

Revised checklists to provide
more detail around the submission
of information for this element
and how issuers must indicate
which QIS submissions apply to
which health plans it offers.

Page 6 of 12

Issue
#
23.

Page #
6

Section
Element #22 –
Rational for QIS

Action to be
performed
Revise
element name
and
instructions

Changes to the Template





24.

6

Element #22 –
Rationale for QIS

Increase
character limit



Add “Must Pass”
Delete “Provide a rationale that addresses 1) the
needs of its current enrollee population; and 2)
health and health care disparities within the
context of the selected topic area(s).”
Replace with “Provide a rationale for the QIS that
addresses all of the following criteria:
22a – How will the QIS address the needs of the
current Marketplace population?
22b – If health and health care disparities is not
one of the topic areas selected (Element 20), how
will the QIS address health and health care
disparities?”
Increase character limit from 500 total to 1,000
for each of two rationales in this element (22a and
22b)

Reason for the Change
Revised instructions to clarify
what information issuers must
submit for this element. (Editorial,
non-substantive changes.)

Revised based on technical expert
panel feedback that 500 characters
was insufficient for issuers to
provide adequate information on
this element.

Page 7 of 12

Issue
#
25.

Page #
7

Section
Element #23 –
Activity(ies) that Will
Be Conducted to
Implement the QIS

Action to be
performed
Revise
instructions

Changes to the Template



Add “Must Pass”
Revise element name from “Activity(ies)
Designed to Meet Strategy Performance Targets”
to “Activity(ies) that Will Be Conducted to
Implement the QIS (Must Pass)”
 Delete “Provide information on how each activity
will:
o Be tied to receiving the market-based
incentive
o Relates to the selected topic area(s) (see item
15)
o Will target health and health care disparities
(see item 16)
o Drive progress in the performance targets
related to selected quality measures (see item
20)
Replace with
 “List the activities implemented to achieve the
identified goals. Describe how the activities
advance the QIS as it relates to each of the
following:”
o 23a – Market-based incentive selected (see
Element 19);
o (1,000 character limit)
o 23b –Topic area(s) selected (see Element 20);
and
o 23c – Health and health care disparities (if not
selected as a separate topic area in Element
20).
 Add “List the Activities”
 Add 23a: “Describe how the activities relate to
the selected market-based incentive;”
 Add 23b: “Describe how the activities relate to
the selected topic area(s);” and
 Add 23c: “Describe how the activities relate to
health and health care disparities (if not selected
as a topic area).”

Reason for the Change
Revised instructions to clarify
what information issuers must
submit for this element. (Editorial,
non-substantive changes.)

Page 8 of 12

Issue
#
26.

Page #

Section

Action to be
performed
Decrease
character limit

7

Element #23 –
Activity(ies) that Will
Be Conducted to
Implement the QIS

27.

7-10

Element #24 –
Goal(s), Measure(s),
and Performance
Target(s) to Monitor
QIS Progress

Revise
instructions

28.

10

Element #25 –
Timeline for
Implementing the QIS

Revise
instructions

29.

10

Element #25 –
Timeline for
Implementing the QIS

Decrease
character limit

Changes to the Template


Reason for the Change

Decreased character limit based on
feedback that 1,000 characters
each would be adequate for issuers
to provide information for 23a,
23b, and 23c.
Restructured and added space for
 Add “Must Pass”
multiple goals/measures, because
 Add clarifying language and revised structure
to specify the type of information issuers must some issuers may provide
provide for the measures used to track progress information for more than one
goal in their QIS (though they are
against the goals identified in element #18.
only required to have one).
 Add space for issuers to provide information
Primarily structural, nonon measures regarding multiple goals.
substantive revisions (“spreading
 Revise instructional language for providing
out” the information for clarity
measure name, description, baseline results,
and organization).
performance period, and performance target.
 Delete “Provide the start date for implementation Revised instructions to clarify
what information issuers must
of strategy and defined milestones, including
submit for this element. (Editorial,
implementation of activities and measurement
non-substantive changes.)
updates.
 Replace with “Provide information regarding the
following criteria:
25a – The start date for QIS implementation; and
25b – Dates for defined milestones (e.g., when
updated measure results will be available to
assess progress).
Decrease character limit from 1,000 to 100.
Decreased based on revised
instructions and updated fields,
which clarify that narrative detail
is not necessary. Also, reduced
based on feedback that issuers
would only need 100 character to
provide this information.
Decrease character limit from 4,000 to 3,000 total
for this element (1,000 characters each for 23a,
23b, and 23c)

Page 9 of 12

Issue
#
30.

Page #
11

Section
Element #26 – Risk
Assessment

Action to be
performed
Revise
element name
and
instructions

Changes to the Template





31.

11

QIS Progress Report – Change name
Part F. Progress
and add
Report Summary
introductory
instructions

32.

11

33.

11-12

Formerly Reporting
Template Element
#14
Formerly Reporting
Template Element
#15






Move element



Move element



Change element name from “Anticipated
Barrier(s) and Mitigation Activities” to “Risk
Assessment”
Delete “List any known or anticipated barriers in
implementing strategy activities. For each barrier
identified, describe the mitigation activities that
are incorporated into the strategy.”
Replace with “Provide information regarding
anticipated barrier(s) and mitigation activities
26a – List any known or anticipated barriers in
implementing QIS activities; and
26b – For each barrier identified, describe the
mitigation activities that will be incorporated into
the QIS if needed.”
Add 1,500 character limit (each) for 26a and 26b
Delete “Strategy Progress”
Replace with “Progress Report Summary”
Add “These fields will be scored as part of the
QIS evaluation. Elements marked “must pass” are
elements that must receive a “meets” during the
QIS evaluation. If any “must pass” elements are
scored as “does not meet” in the QIS evaluation,
the issuer must revise its Progress Report and
submit it for re-review.”
Remove “Continue Implementing Current
Strategy or Submitting a New Strategy for
Approval”
Remove “Activities Related to Implementing
Strategy”

Reason for the Change
Revised instructions to clarify
what information issuers must
submit for this element. (Editorial,
non-substantive changes.)
Provided specific character limit
in response to feedback that the
responses to this element should
be limited.

Added to clarify the purpose of the
section and that the fields in this
section will be scored.

Removed because this information
is now requested in Part A,
Element #1.
Removed because this information
is now requested in Part E,
Element #23.

Page 10 of 12

Issue
#
34.

Page #

Section

Action to be
performed
New element

Changes to the Template


12

Element #27 Addition of Health
Plans to the Issuer’s
QIS

35.

12

Element #28 - QIS
Modifications

New element



36.

13-14

Element #29 –
Analyze Progress
Using Baseline Data,
as Documented in
Implementation Plan

Revise
instructions
and structure






Add “Addition of Health Plans to the Issuer’s
QIS. 27a – Check “Add health plan(s)” if the
issuer is adding health plans to its existing QIS.
Check “No additional health plans” if the issuer is
not adding any health plans to its existing QIS.
27b – If “Add health plan(s)” was selected, list all
new health plans and provide each plan’s 14-digit
unique HIOS Plan ID (Standard Component ID).
Select “Not Applicable” if no new health plans
were included.
Add “28a. If “Continuing a QIS with
Modifications” was selected in Element 1, please
indicate what type of modification the issuer is
making to its QIS. (Check all that apply.)
If “Continuing a QIS with Modifications” was not
selected in Element 1, check “Not Applicable.”
28b. Provide a justification and brief description
of the modification(s) selected in criterion 28a.
Check “Not Applicable” if no modifications
were/will be made.

Add clarifying language and revised structure to
specify the type of information issuers must
provide for reporting progress against goals using
the measures identified in their Implementation
Plans.
Add space for issuers to provide information on
progress regarding multiple goals.
Revise instructional language for providing
progress analysis.

Reason for the Change
Added because it is necessary to
collect this information in
subsequent years as part of
issuer’s Progress Report to verify
whether the portfolio of QHPs
changed since the previous
submission since all QHPs must
be covered by a QIS.

Added because it is necessary to
collect this information in
subsequent years as part of
issuer’s Progress Report to
understand whether modifications
are being implemented in the
following year. An issuer does not
need to resubmit an
Implementation Plan if it is
making minimal modifications;
thus the reason for putting this in
the Progress Report.
Restructured and added space for
multiple goals/measures, because
some issuers may provide
information for more than one
goal in their QIS (though they are
only required to have one).
Primarily structural, nonsubstantive revisions (“spreading
out” the information for clarity
and organization).

Page 11 of 12

Issue
#
37.

38.

Page #

Section

14

Element #30 –
Summary of Progress

15

Element #31 –
Barriers

Action to be
performed
New element

Revise
instructions

Changes to the Template






39.

15

Element #32 –
Mitigation Activities

Revise
instructions






Add “30a -- Summary of progress, including
reasons why progress was or was not made
toward the performance target(s) documented in
Element 24. Include a description of activities
that led to the outcome.
If applicable, indicate whether the information
provided here affects the decision to modify or
change the QIS.
Delete “Challenges” from element name
Delete “Indicate if barriers were encountered
when implementing the strategy. (Check box)”
Add “31a – Check the appropriate box to indicate
if barriers were encountered when implementing
the QIS.
31b – Check the appropriate box to indicate if
there were problems meeting timelines.
31c – If “Yes” was selected in 31a or 31b,
describe the barriers and/or problems in
implementing the QIS or meeting timelines. If
“No” was selected in 31a or 31b, select “Not
Applicable.””
Delete “to address Barriers Encountered” from
element name
Delete “Describe the barriers and the
implementation of mitigation activities
implemented to address each of the barriers, as
well as the result(s) of the mitigation strategy.”
Add “32a – If “Yes” was selected in 31a or 31b,
describe the mitigation activities implemented to
address each barrier or problem in meeting the
timeline. Also, describe the result(s) of the
mitigation activities. If “No” was selected in 31a
and 31b, select “Not Applicable.””

Reason for the Change
Added to collect summary
information on why an issuer did
or did not achieve its goal(s) in
subsequent years as part of
issuer’s Progress Report.

Revised instructions to clarify
what information issuers should
submit for this element. (Editorial,
non-substantive changes.)

Revised instructions to clarify
what information issuers should
submit for this element. (Editorial,
non-substantive changes.)

Page 12 of 12