Crosswalk QIS Form

Crosswalk for Changes to the Quality Improvement Strategy (QIS) Implementation Plan and
Progress Report Form (CMS-10540)
The following table contains the list of changes made to the proposed QIS Implementation Plan and Progress Report form for the 2020 Plan Year.
Issue
#
1.

Page #

2.

1

Element #1 (Type of
QIS Submission)

Add new
option

3.

2

Move Element •
to different
section

4.

2

Part A – New,
Discontinuing, or
Continuing QIS
Submission
Criterion #2a: Targets
All Health Plans and
Product Types
Offered Through an
Exchange

All

Section
All

Action to be
Performed
Revise
language

Add footnote
to clarify
requirements

Changes to the QIS Form

Reason for the Change

•

Make minor language changes throughout.

•

Add option “Discontinuing a QIS Submitted
during a prior Qualified Health Plan (QHP)
Application Period” to Part A.
Move former Element #21 (Targets All Health
Plans and Product Types Offered Through an
Exchange) from former Part E to Part A.

To improve clarity and readability
and improve consistency with
updated Agency language.
To improve clarity of submission
type.

•

Add footnote in new Criterion #2a: “An issuer
that previously covered all eligible QHPs with a
single QIS may choose to cover a subset of QHPs
with its existing QIS in subsequent years, but
must submit an additional QIS form(s) to cover
its remaining eligible QHPs. Similarly, an issuer
that previously covered subsets of its eligible
QHPs with different quality improvement
strategies may discontinue one or more of its
strategies by submitting QIS forms to close them
out. The issuer must also ensure all eligible QHPs
are covered by an existing or new QIS.”

To improve clarity and
readability.

To prevent user confusion and
errors.

Page 1 of 5

Issue
#
5.

Page #

6.

3

7.

4

8.

5

9.

7

10.

10

N/A

Section

Action to be
Changes to the QIS Form
Performed
Modify
Part A − New or
• Remove former Criterion #21b: “In the space
former
provided, specify all eligible QHPs covered by
Continuing QIS
Element
#21
the QIS by listing each plan’s unique 14-digit
Submission
(new Element
HIOS Plan ID (Standard Component ID [SCID]).
#2)—remove
Indicate if each one is a new or existing eligible
former
QHP. For initial submissions, specify all eligible
Criterion #21b
QHPs covered by the QIS. To update a prior QIS
submission by adding or removing SCIDs, use
Element #27. Note: Please list additional health
plans covered by the QIS on pages 26 and 27.”
Part B – Issuer
Add clarifying • Add clarifying language, “Issuers may update the
Information
instructions
information in Part B from year to year, as
needed” to instructions in Part B.
Element #16:
Modify
• Add clarifying language, “Provide the percentage
(Current Payment
Element
of payments in each payment model category
Model(s)
used by the issuer across its Exchange product
Description)
line,” to Element #16 (Current Payment Model(s)
Description).
• Add boxes to capture percentage of each payment
model type.
• Add footnote to clarify how to calculate the
percentage of payments.
Part C – Data Sources Add clarifying • Add “Issuers may update the information in Part
Used for Goal
instructions
C from year to year, as needed” to instructions in
Identification and
Part C.
Monitoring Progress
Element #19: (QIS
Revise
• Delete “Measures described in Element 24 should
Description)
language
be linked to these goals.”
• Replace with “The topic area(s) selected in
Element 21 and the measures described in
Element 24 should be linked to these goals.”
Element #22:
Revise
• Modify language to say, “Provide a rationale for
(Rationale for QIS)
language
the QIS that describes the issuer’s current QHP
enrollee populations and how the QIS will
address the needs of the current QHP enrollee
population(s).”

Reason for the Change
To prevent user confusion and
errors, former Element #21 was
modified to remove former
Criterion #21b, which addressed
the collection of SCIDs. CMS has
alternate methods to check SCIDs
for compliance.

To prevent user confusion and
errors.
To prevent user confusion and
errors.

To prevent user confusion and
errors.

To improve clarity and
readability.

To improve clarity and
readability.

Page 2 of 5

Issue
#
11.

Page #

12.

10-11

13.

12

14.

11-16

10

Section
Element #22
(Rationale for QIS)

Action to be
Changes to the QIS Form
Performed
Increase
• Increase character limit from 1,000 characters to
character limit
1,500 characters.

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

Increase
•
character limit

Revise
language

•

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

Revise
language

•

•
•

15.

18

Element #26 (Risk
Assessment)

Revise
language and
add a text box

•
•
•

Increase character limit from 1,000 characters to
1,500 characters.

Modify language to say, “If the issuer did not
choose health and health care disparities as a
topic area in Element #21, but the QIS does
include activities related to addressing health and
health care disparities, describe the activities
below. If (1) health and health care disparities is
one of the topic areas selected in Element #21;
OR (2) health and health care disparities are not
addressed in this QIS, check  Not Applicable.”
Modify language to say, “Baseline Assessment.
Provide the baseline results by calculating the rate
and providing the associated numerator and
denominator, if applicable.”
Remove “Not Applicable” checkboxes from
questions regarding National Quality Forum
(NQF) endorsement.
Add language: “If the measure is not a rate, but
another data point, enter the number in the space
provided.”
Add field to capture Data Point.
Add language: “If no barriers were identified,
describe how you assessed risk.”
Add text box to capture description.

Reason for the Change
As a response to issuer feedback,
the character limit was increased
in Element #22.
As a response to issuer feedback,
the character limit was increased
in Element #23.
To improve clarity and
readability.

To improve clarity and readability
and to prevent user error and
confusion.

To improve clarity and
readability.

Page 3 of 5

Issue
#
16.

Page #

17.

N/A

Element #27
(Addition of QHPs to
the Issuer’s QIS)

18.

N/A

Remove Element #28 (QIS Modifications)

19-20

Remove
Element
Add Part

•

19.

Element #28 (QIS
Modifications)
Part F: QIS
Modification
Summary

•

20.

20

20-24

Change radio
buttons to
checkboxes
Revise
language

•

21.

Element #28
(Modifying Product
Types)
Element #29 (Analyze
Progress Using
Baseline Data, as
Documented in the
Implementation Plan)

Add Part F: QIS Modification Summary,
including Element #27 (Modifying Goals,
Measures, and Activities) and Element #28
(Modifying Product Types)
Modify Element to have checkboxes, so issuers
can simultaneously select “Add” and “Remove”
product types.
Modify language in Criterion #29d to say,
“Restate the baseline results from Criterion 24c of
your most recent QIS submission, including the
rate and associated numerator and denominator, if
applicable.”
Add language “If the measure is not a rate, but
another data point, enter the number in the space
provided.”
Add field to capture data point.

18

Section
Part E. QIS
Requirements

Action to be
Changes to the QIS Form
Performed
Add clarifying Add:
instructions
• If “New QIS with No Previous QIS submission,”
STOP HERE.
• If “New QIS after Discontinuing,” STOP HERE.
• If “Discontinuing a QIS,” SKIP to page 21 (Part
G. Progress Report Summary).
• If “Continuing a QIS with Modifications,”
continue to next page 19 (Part F. Modification
Summary).
• If “Continuing a QIS with No Modifications,”
SKIP to page 21 (Part G. Progress Report
Summary).
Remove
• Remove Element #27 (Addition of QHPs to the
Element
Issuer’s QIS)

•

•
•

Reason for the Change
To improve clarity and prevent
user confusion and errors.

As a response to issuer feedback,
Element #27 was removed
because it addresses the collection
of SCIDs.
Element #28 was removed to
eliminate redundancies.
Added elements to improve
clarity and prevent user confusion
and error.
To improve clarity and
readability.
To prevent user confusion and
errors.

Page 4 of 5

Issue
#
22.

Page #
25

Section
Element #30
(Summary of
Progress)

Action to be
Performed
Revise
language

Changes to the QIS Form

Reason for the Change

•

To improve clarity and
readability.

•

•

Element #30
(Summary of
Progress)
Element #32
(Mitigation Activities)

Increase
•
character limit

26

Criterion #32b

Revise
language

•

N/A

Criterion #21b,
Criterion #27b

Remove
Criteria

•

23.

25

24.

26

25.

26.

Increase
•
character limit

Modify language to say, “Indicate 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,
and, if applicable, indicate whether the
information provided here affects the decision to
modify the QIS (Part F).”
Add language: “If the issuer selected
"Discontinuing a QIS Submitted During a Prior
QHP Application Period" in Element 1, provide
the rationale for discontinuing the QIS.”
Add language: “If applicable, provide information
about changes made based on Post-certification
Assessment (PCA) Reports from the previous
year.”
Increase character limit from 1,500 characters to
3,000 characters.

As a response to issuer feedback,
the character limit was increased
in Element #30.
As a response to issuer feedback,
Increase character limit from 750 characters to
the character limits were
1,500 characters.
increased in Element #32.
Modify language to say, “If “Yes” was selected in To improve clarity and
readability.
#31b, describe the mitigation activities
implemented to address each problem in meeting
the timeline. Also, describe the result(s) of the
mitigation activities. If “No” was selected in
#31b, check  Not Applicable.”
As a response to issuer feedback,
Remove Criterion #21b and Criterion #27b
extra pages regarding Criterion
#21b and Criterion #27b were
removed because they address the
collection of SCIDs.

Page 5 of 5