Memo - Updated Requirements for Reporting of 2020 Measures

DEPARTMENT OF HEALTH & HUMAN SERVICES
CENTERS FOR MEDICARE & MEDICAID SERVICES
7500 SECURITY BOULEVARD
BALTIMORE, MARYLAND 21244-1850

CENTER FOR MEDICARE
DATE:

September 9, 2019

TO:

All Medicare Advantage Organizations, Cost Plans, PACE Organizations, and
Demonstrations

FROM:

Amy Larrick Chavez-Valdez
Director, Medicare Drug Benefit and C & D Data Group
Kathryn A. Coleman,
Director, Medicare Drug & Health Plan Contract Administration Group

SUBJECT: Reporting Requirements for 2020 HEDIS®, HOS, and CAHPS® Measures
Overview
This memorandum contains the Healthcare Effectiveness Data and Information Set (HEDIS)
measures required for reporting in 2020 by all Medicare Advantage Organizations (MAOs) and other
health plan organization types (Table 1). It also includes information about which contracts are
required to participate in the Medicare Health Outcomes Survey (HOS) and Consumer Assessment of
Healthcare Providers and Systems (CAHPS) Survey.
Sections 422.152 and 422.516 of Volume 42 of the Code of Federal Regulations (CFR) state that
contracts must submit quality performance measures as specified by the U.S. Department of Health &
Human Services (DHHS) Secretary and the Centers for Medicare & Medicaid Services (CMS).
This memorandum supersedes the reporting requirements for HEDIS, HOS, and CAHPS in the CMS
Medicare Managed Care Manual (any volume) or other sources.
HEDIS 2020 Requirements
As part of the clinical quality reporting requirements, in 2020 (the reporting year) Medicare health
plans must submit their HEDIS data to the National Committee for Quality Assurance (NCQA)
covering the 2019 measurement year. Detailed specifications for HEDIS measures are included in
HEDIS 2020, Volume 2: Technical Specifications for Health Plans.
All HEDIS 2020 audited summary-level data must be submitted to NCQA by 11:59 p.m.
Eastern Time on Monday, June 15, 2020. There are no late submissions. As a reminder CMS will
reduce HEDIS measures to 1 star, as specified at §422.164(g)(1), when any HEDIS measures used to
populate the Star Ratings are not reported. For Medicare-Medicaid Plans (MMPs), failure to report
HEDIS measures may affect quality withhold payments, as articulated in the CMS Core Quality
Withhold Technical Notes.
All health plan organizations that are new to HEDIS must become familiar with the requirements for
data submission to NCQA and make the necessary arrangements as soon as possible. Information
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about the HEDIS audit compliance program is available at https://www.ncqa.org/programs/data-andinformation-technology/hit-and-data-certification/hedis-compliance-audit-certification/.
For the 2020 reporting year, MAOs and other health plan organization types listed in Table 1 must
submit audited summary-level data to NCQA. Table 1 also indicates which organization types must
report CAHPS, HEDIS, HOS, and HOS-M data.
Table 1: 2020 Performance Measure Reporting Requirements
Organization Type
CAHPS HEDIS HOS HOS-M




Section 1876 Cost contracts
Chronic Care








Demonstration: Medicare-Medicaid Plans (MMPs)
Employer/Union Only Direct Contract Local CCP




Employer/Union Only Direct Contract PFFS




HCPP-1833 Cost








Local Coordinated Care Plans (LCCP)
Medical Savings Account (MSA)




PACE




Private Fee-for-Service (PFFS)




Regional Coordinated Care Plans (RCCP)




Religious Fraternal Benefit Local Coordinated Care Plans (RFB CCP)








Religious Fraternal Benefit Private Fee-for-Service
 = Not required to report
 = Required to report
HEDIS 2020 Summary Contract-Level Data
CMS requires all contracts with an effective date of January 1, 2019 or earlier, that have an
organization type marked in Table 1, to collect and submit to NCQA the audited summary contractlevel data for the HEDIS measures listed in Table 2. There is no minimum enrollment requirement
for submitting audited summary-level data.
Contract Closures: If your Health Plan Management System (HPMS) contract status becomes
“Withdrawn Contract” or “Terminated” with a termination date on or before the June 15, 2020
submission date, then your contract is not required to report for HEDIS 2020. MMPs that terminate as
of December 31, 2019 or after, however, are required to report for HEDIS 2020 if they were in
operation for the full 2019 contract year. 1876 Cost contracts that are terminating as of December 31,
2019 and are transferring their enrollees into a MA contract which does not have sufficient data to
earn their own 2021 Star Ratings may submit their 2020 HEDIS cost contract data to NCQA. All 1876
Cost contracts are required to report the HEDIS measures listed in Table 2, regardless of enrollment
closure status. See the footnote at the bottom of Table 2 for exceptions to measures 1876 Cost contracts
report.
Contract Consolidations: If your organization consolidates one or more contracts during the change over
from measurement to reporting year, then only the surviving contract is required to report audited
summary contract-level data including all members from all contracts involved in the consolidation.
Contract Merger or Novation: Organizations that merge or novate at any time throughout the
measurement year up until the time of reporting must report audited summary contract-level HEDIS
data for each contract in the organization.

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Table 2: HEDIS 2020 MA Contract Level Measures for Reporting

HEDIS 2020 MA Contract Level Measures for Reporting:
All organizations report all measures except as noted in the footnotes
Effectiveness of Care
ABA
BCS
COL
SPR
PCE
CBP
PBH
SPC
CDC
SPD
ART
OMW
AMM
FUH
FUM
FUA
SAA
MRP
TRC
FMC
PSA
DDE
DAE
HDO
UOP
HOS
FRM
MUI
OTO
PAO
FVO
MSC
PNU

Adult BMI Assessment
Breast Cancer Screening
Colorectal Cancer Screening
Use of Spirometry Testing in the Assessment and Diagnosis of Chronic Obstructive
Pulmonary Disease (COPD)
Pharmacotherapy Management of COPD Exacerbation
Controlling High Blood Pressure
Persistence of Beta-Blocker Treatment After a Heart Attack1
Statin Therapy for Patients with Cardiovascular Disease1
Comprehensive Diabetes Care2
Statin Therapy for Patients With Diabetes1
Disease-Modifying Anti-Rheumatic Drug Therapy for Rheumatoid Arthritis
Osteoporosis Management in Women Who Had a Fracture
Antidepressant Medication Management
Follow-Up After Hospitalization for Mental Illness
Follow-Up After Emergency Department Visit for Mental Illness
Follow-Up After Emergency Department Visit for Alcohol and Other Drug Abuse or
Dependence
Adherence to Antipsychotic Medications for Individuals with Schizophrenia
Medication Reconciliation Post-Discharge1
Transitions of Care1
Follow-up After Emergency Department Visit for People with Multiple High-Risk Chronic
Conditions
Non-Recommended PSA-Based Screening in Older Men
Potentially Harmful Drug-Disease Interactions in the Elderly
Use of High-Risk Medications in the Elderly
Use of Opioids at High Dosage
Use of Opioids from Multiple Providers
Medicare Health Outcomes Survey
Falls Risk Management (collected in HOS)
Management of Urinary Incontinence in Older Adults (collected in HOS)
Osteoporosis Testing in Older Women (collected in HOS)
Physical Activity in Older Adults (collected in HOS)
Flu Vaccinations for Adults Ages 65 and Older (collected in CAHPS)
Medical Assistance With Smoking and Tobacco Use Cessation (collected in CAHPS)
Pneumococcal Vaccination Status for Older Adults (collected in CAHPS)
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HEDIS 2020 MA Contract Level Measures for Reporting:
All organizations report all measures except as noted in the footnotes
Access/Availability of Care
AAP
IET

Adults’ Access to Preventive/Ambulatory Health Services
Initiation and Engagement of Alcohol and Other Drug Abuse or Dependence Treatment
Utilization and Risk Adjusted Utilization

FSP
IAD
MPT
ABX
PCR
HFS
AHU
EDU
HPC

Frequency of Selected Procedures1
Identification of Alcohol and Other Drug Services1
Mental Health Utilization1
Antibiotic Utilization
Plan All-Cause Readmissions1
Hospitalization Following Discharge from a Skilled Nursing Facility1,3
Acute Hospital Utilization1
Emergency Department Utilization1
Hospitalization for Potentially Preventable Complications1
Health Plan Descriptive Information

LDM Language Diversity of Membership
TLM Total Membership
Measures Collected Using Electronic Clinical Data Systems 4
BCS-E
COL-E
DSF
DMS
DRR
ASF
AIS

1

2
3

4

Breast Cancer Screening
Colorectal Cancer Screening
Depression Screening and Follow-Up for Adolescents and Adults
Utilization of the PHQ-9 to Monitor Depression Symptoms for Adolescents and Adults
Depression Remission or Response for Adolescents and Adults
Unhealthy Alcohol Use Screening and Follow-Up
Adult Immunization Status (incorporates the former Pneumococcal Vaccination Coverage for
Older Adults (PVC) measure)

Section 1876 Cost contracts do not report the following measures: PCE, PBH, SPC, SPD,
MRP, TRC, FSP, IPU, IAD, MPT, PCR, HFS, AHU, EDU, and HPC.
HbA1c control <7% for a selected population is not reported for Medicare contracts.
The Standardized Healthcare-Associated Infection Ratio measure (HAI) and the Hospitalization
Following Discharge from a Skilled Nursing Facility (HSF) will NOT be reported in the 2020
HEDIS PLD.
Reporting the measures in the Electronic Clinical Data Systems (ECDS) set is voluntary; however,
if they are reported, they must be audited. CMS is collecting these data for review only. The ECDS
measures will NOT be included in the Patient-Level Data in HEDIS 2020. The data collected for
these measures will NOT be included in any publicly-reported data.

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HEDIS 2020 Patient-Level Data (PLD)
All organizations that submit HEDIS summary contract-level data are also required to submit
audited HEDIS Patient-Level Data (PLD) files to the designated CMS contractor. All HEDIS PLD
files must be submitted by 11:59 p.m. Eastern Time on June 15, 2020. Late submissions are not
permissible. CMS expects these PLD files to contain the member level details for the data reported
in the contracts’ HEDIS summary data submissions.
CMS will send an additional HPMS Memorandum later in 2019, which will reiterate the list of
required measures for data collection and will provide links to the specific instructions about the
data collection and data submission of HEDIS PLD.
2020 Summary PBP-Level Reporting for CCPs with SNPs and MMPs
In 2020, CMS will continue collecting audited summary plan benefit package (PBP) level data from
each PBP designated as a SNP offered by any CCP organization. CMS will also collect audited
summary PBP level data for each MMP PBP.
A SNP PBP must have had 30 or more members enrolled as listed in the February 2019 SNP
Comprehensive Report (this report can be found at this link: http://www.cms.gov/ResearchStatistics-Data-and-Systems/Statistics-Trends-and-Reports/MCRAdvPartDEnrolData/Special- NeedsPlan-SNP-Data.html). SNP PBPs that meet the enrollment criteria must also exist in both the
measurement year and reporting years. PBPs that terminated as of December 31, 2019 are not
required to report but may still do so voluntarily.
An MMP PBP must have had 30 or more members enrolled as listed in the February 2019 Monthly
Enrollment by Plan report (this report can be found at this link: http://www.cms.gov/ResearchStatistics-Data-and-Systems/Statistics-Trends-and-Reports/MCRAdvPartDEnrolData/MonthlyEnrollment-by-Plan.html). MMP PBPs that terminated as of December 31, 2019 or after are required
to report, if they were in operation for the full 2019 calendar year.
All SNP and MMP PBPs must report the HEDIS measures in Table 3. If a contract has multiple
qualifying PBPs, then each qualifying PBP in the contract must report the measures in Table 3 in a
separate submission. MMP and contracts with SNP PBPs do not have to report any additional PLD
files. The required HEDIS PLD file submission at the contract level will already include the detail data
about the members in the SNP and MMPs PBPs. Table 3 lists the 2020 HEDIS measures for reporting
by all SNP and MMP PBPs.

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Table 3: HEDIS 2020 Measures for Reporting by SNPs and MMP PBPs

HEDIS 2020 Plan Benefit Package (PBP) Level Measures for Reporting:
All SNP & MMP PBPs Report All Measures
Effectiveness of Care
COL Colorectal Cancer Screening
COA Care for Older Adults (SNP- and MMP-only measure)
Use of Spirometry Testing in the Assessment and Diagnosis of Chronic
SPR
Obstructive Pulmonary Disease (COPD)
PCE Pharmacotherapy Management of COPD Exacerbation
CBP Controlling High Blood Pressure
PBH Persistence of Beta-Blocker Treatment After a Heart Attack
OMW Osteoporosis Management in Women Who Had a Fracture
AMM Antidepressant Medication Management
FUH Follow-Up After Hospitalization for Mental Illness
MRP Medication Reconciliation Post-Discharge
DDE Potentially Harmful Drug-Disease Interactions in the Elderly
TRC Transitions of Care
DAE Use of High-Risk Medications in the Elderly
Utilization and Risk Adjusted Utilization
PCR Plan All-Cause Readmissions

HEDIS Contacts
Please send all questions about HEDIS measure specifications to NCQA’s Policy Clarification
Support system at my.ncqa.org. For other CMS information about HEDIS, please email
[email protected].

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2020 HOS and HOS-M Reporting Requirements
Who Must Report HOS
The following types of MAOs and other health plan organization types with Medicare contracts in
effect on or before January 1, 2019 are required to report the Baseline HOS in 2020, provided that
they have a minimum enrollment of 500 members as of February 1, 2020:
•
•
•
•

All MAOs, including all coordinated care plans, PFFS contracts, and MSA contracts
Section 1876 Cost contracts even if they are closed for enrollment
Employer/union only contracts
Medicare Medicaid Plans (MMPs)

In addition, all organizations that reported a Cohort 21 Baseline Survey in 2018 are required to
administer a Cohort 21 Follow-up Survey in 2020. In the event of a contract consolidation, merger or
novation, the surviving contract must report Follow-Up HOS for all members of all contracts
involved. All eligible members of consolidated, merged, or novated contracts will be resurveyed and the
results will be reported as one under the surviving contract. In the event of a contract conversion, the
contract must report if their new organization type is required to report.
As a reminder, CMS will exclude beneficiaries enrolled in I-SNPs at the PBP level from HOS Baseline
beginning in 2020. HCPP 1833 Cost contracts are also excluded from the HOS administration.
Organizations are required to contract with a CMS-approved HOS survey vendor and to notify
NCQA of their survey vendor choice no later than January 10, 2020. Approved 2020 HOS survey
vendors will be listed on www.HOSonline.org. You will receive further correspondence from
NCQA regarding your HOS participation. As a reminder, CMS will reduce any HOS Star Ratings
measures to 1 star for failure to adhere to HOS reporting requirements, as detailed at §422.164(g)(2).
Optional Reporting for FIDE SNPs
MAOs sponsoring fully integrated dual eligible (FIDE) SNPs may elect to report HOS at the plan
benefit package level to determine eligibility for a frailty adjustment payment under the Affordable
Care Act. Voluntary reporting at the plan level will be in addition to standard HOS requirements for
quality reporting at the contract level. Plans may elect to report HOS-M if they meet certain criteria.
Information specific to optional reporting for FIDE SNPs in 2020 will be forthcoming in a separate
memo.
Who Must Report HOS-M
The HOS-M is an abbreviated version of the Medicare HOS. The HOS-M assesses the physical and
mental health functioning of the beneficiaries enrolled in Programs of All-Inclusive Care for the
Elderly (PACE) to generate information for payment adjustment.
All PACE Medicare contracts in effect on or before January 1, 2020 are required by CMS to
administer the HOS-M survey in 2020 if they have a minimum enrollment of 30 members.
To report HOS-M, eligible plans must contract with the CMS-approved HOS-M survey vendor no
later than January 10, 2020. You will receive further correspondence from NCQA regarding your
HOS-M participation.
For additional information on the HOS survey, please email [email protected].
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2020 CAHPS Survey Requirements
The following types of organizations are included in the CAHPS survey administration if they have a
minimum enrollment of 600 eligible members as of July 1, 2019:
•
•
•
•

All MAOs, including all coordinated care plans, PFFS contracts, and MSA contracts
Section 1876 Cost contracts even if they are closed for enrollment
Employer/union only contracts
Medicare-Medicaid Plans

PACE and HCPP 1833 Cost contracts are excluded from the CAHPS administration. Beneficiaries
enrolled in I-SNPs are excluded from sampling.
Organizations are required to contract with an approved MA & PDP CAHPS vendor for the 2020
CAHPS survey administration. All approved CAHPS survey vendors for the 2020 survey
administration will be listed on www.MA-PDPCAHPS.org. CMS will issue additional HPMS
memorandums about the CAHPS survey for 2020.
As a reminder CMS will reduce any CAHPS Star Ratings measures to 1 star for failure to adhere to
CAHPS reporting requirements as detailed at §422.164(g)(2). For MMPs, failure to adhere to CAHPS
reporting requirements may affect quality withhold payments, as articulated in the CMS Core Quality
Withhold Technical Notes.
For additional information on the CAHPS survey, please email [email protected].

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