2025 Final QIS Technical Guidance

CMS- PY2025 Final QIS Technical-Guidance.pdf

Quality Improvement Strategy Implementation Plan and Progress Report (CMS-10540)

2025 Final QIS Technical Guidance

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Health Insurance Exchange

Quality Improvement Strategy:
Technical Guidance and User Guide
for the 2025 Plan Year

April 2024

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Table of Contents
1.
2.

Technical Assistance Available to Issuers ............................................................................. 1
Document Purpose and Scope ............................................................................................... 3
2.1 Section Guide ............................................................................................................... 3

VOLUME I. QIS TECHNICAL GUIDANCE FOR THE 2025 PLAN YEAR ....................... 5
1.
2.
3.
4.

Background ............................................................................................................................ 6
Technical Guidance Overview............................................................................................... 8
QIS Timeline for the 2025 Plan Year .................................................................................. 10
Exchange Oversight Responsibilities .................................................................................. 10
4.1 Federally-facilitated Exchanges.................................................................................. 10
4.2 State-based Exchanges................................................................................................ 11
QIS Requirements ................................................................................................................ 11
5.1 Participation Criteria................................................................................................... 11
5.2 Calculating the Minimum Enrollment Threshold ....................................................... 13
5.3 QIS Implementation Plan, Progress Report, and Modification Summary
Supplement Forms ...................................................................................................... 15
QIS Completeness Assessment and Evaluation................................................................... 20
6.1 QIS Form Completeness Assessment Process............................................................ 22
6.2 QIS Evaluation Methodology ..................................................................................... 23
6.3 Scoring the QIS Submission ....................................................................................... 23

VOLUME II. QIS USER GUIDE FOR THE 2025 PLAN YEAR .......................................... 28
1.

User Guide Introduction ...................................................................................................... 29
1.1 Access the QIS Materials on the MQI Webpage ........................................................ 29
1.2 Determine Which QIS Form(s) to Complete .............................................................. 29
1.3 Prepare to Complete the QIS Forms ........................................................................... 30
Complete Introductory Sections of the Applicable QIS Forms ........................................... 31
2.1 Part A. QIS Submission Type..................................................................................... 32
2.2 Part B. Issuer Information .......................................................................................... 34
Complete the QIS Implementation Plan Form (Part C. Data Sources, Part D. QIS
Summary, and Part E. QIS Requirements) .......................................................................... 37
3.1 Part C: Data Sources ................................................................................................... 37
3.2 Part D. QIS Summary ................................................................................................. 38
3.3 Part E. QIS Requirements ........................................................................................... 39
Complete the QIS Progress Report Form ............................................................................ 45
4.1 Part A: QIS Submission .............................................................................................. 45
4.2 Part B: Issuer Information .......................................................................................... 45
4.3 Part C. Progress Report Summary .............................................................................. 46

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Complete the QIS Modification Summary Supplement Form ............................................ 49
5.1 Part A: QIS Submission .............................................................................................. 50
5.2 Part B: Issuer Information .......................................................................................... 50
5.3 Part C: QIS Modification Summary ........................................................................... 51
Submit the QIS Form(s)....................................................................................................... 53
6.1 Submit via HIOS ........................................................................................................ 53
6.2 Submit via SERFF ...................................................................................................... 54
Address Incomplete or Deficient QIS Submissions ............................................................ 55
7.1 Addressing Deficiencies During the Current QHP Application Period ..................... 55
7.2 Addressing Concerns After the QHP Application Period .......................................... 56

APPENDICES ............................................................................................................................. 57
Appendix A. Excerpts of Relevant Statutory and Regulatory Citations ....................................... 58
Appendix B. QIS Forms Pre-Submission Checklist ..................................................................... 61
Appendix C. Elements and Criteria .............................................................................................. 63
Appendix D. Scenarios for Form Completion Based on Type of QIS Submission ...................... 78
Appendix E. Market-Based Incentive Examples .......................................................................... 80
Appendix F. Glossary ................................................................................................................... 81
Appendix G. Acronym List........................................................................................................... 85

List of Exhibits
Exhibit 1: Examples of QIS Activities Cited in the Patient Protection and Affordable Care
Act ................................................................................................................................. 7
Exhibit 2: Example Issuer Submissions Assessed Against QIS Participation Criteria ................ 14
Exhibit 3: Application of the Minimum Enrollment Threshold to Progress Reporting ............... 14
Exhibit 4: Type of QIS Submission .............................................................................................. 17
Exhibit 5: Changing Components of a QIS .................................................................................. 19
Exhibit 6: QIS Forms – Sections and Parts................................................................................... 19
Exhibit 7: Completeness Assessment and Evaluation Process ..................................................... 21
Exhibit 8: Corrections Timeline.................................................................................................... 22
Exhibit 9: Implementation Plan Form (Part E) Scored Elements by Type ................................... 24
Exhibit 10: Scoring Scale for Element 26 in the Implementation Plan Form (Part E) ................. 24
Exhibit 11: Progress Report Form (Part C) Scored Elements by Type ........................................ 25
Exhibit 12: Scoring Scale for Element 18 in the Progress Report Form (Part C) ........................ 25
Exhibit 13: Modification Summary Supplement Form (Part C) Scored Elements by Type ........ 25
Exhibit 14: Scoring Designations ................................................................................................. 26
Exhibit 15: CMS QIS Evaluation Results Communication .......................................................... 27
Exhibit 16: QIS Form(s) Selection Decision Tree ........................................................................ 30

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Exhibit 17: Examples of Payment Models by Category ............................................................... 36
Exhibit 18: Patient Protection and Affordable Care Act, 42 U.S.C. Sec. 18031
(March 23, 2010) ........................................................................................................ 58
Exhibit 19: Patient Protection and Affordable Care Act; Establishment of Exchanges and
Qualified Health Plans; Exchange Standards for Employers, Final Rule, 77 Fed.
Reg. 18310-18475 (March 27, 2012).......................................................................... 58
Exhibit 20: Patient Protection and Affordable Care Act; Exchange and Insurance Market
Standards for 2015 and Beyond, Final Rule, 79 Fed. Reg. 30240-30353
(May 27, 2014)............................................................................................................ 59
Exhibit 21: Patient Protection and Affordable Care Act; HHS Notice of Benefit and
Payment Parameters for 2016, Final Rule, 80 Fed. Reg. 10750-10877 (February
27, 2015) ..................................................................................................................... 60
Exhibit 22: Patient Protection and Affordable Care Act; HHS Notice of Benefit and
Payment Parameters for 2023, Final Rule, 87 Fed. Reg. 27208-27393 (May 6,
2022) ........................................................................................................................... 60
Exhibit 23: Implementation Plan Form and Progress Report Form Pre-Submission
Checklist ..................................................................................................................... 61
Exhibit 24: QIS Implementation Plan Form Elements and Criteria ............................................. 63
Exhibit 25: QIS Progress Report Form Elements and Criteria ..................................................... 71
Exhibit 26: QIS Modification Summary Supplement Form Elements and Criteria ..................... 75
Exhibit 27: Scenarios for Form Completion Based on Type of QIS Submission ........................ 78
Exhibit 28: Examples and Definitions of Market-Based Incentives for Providers ....................... 80
Exhibit 29: Examples and Definitions of Market-Based Incentives for Exchange Enrollees ...... 80
Exhibit 30: Glossary ..................................................................................................................... 81
Exhibit 31: Acronym List ............................................................................................................. 85

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Technical Assistance Available to Issuers

Technical assistance is available for issuers, Health Insurance Exchanges (Exchanges), 1 and
other entities that may have questions related to the quality improvement strategy (QIS)
requirements for Qualified Health Plans (QHPs) offered through the Exchanges.
•
•
•
•

QHP issuers: Please submit questions to the Marketplace Service Desk (MSD) via email to
[email protected] or via phone at 1-855-CMS-1515 (1-855-267-1515). Please
reference “Marketplace Quality Initiatives (MQI)-QIS” in the subject line.
State-based Exchanges (SBEs): Please submit questions to your respective State Officers.
Federally-facilitated Exchanges (FFEs): Please submit questions via email to the MSD at
[email protected] and reference “Marketplace Quality Initiatives (MQI)-QIS” in the
subject line.
Other interested parties: Please submit questions via email to
[email protected] and reference “Marketplace Quality Initiatives
(MQI)-QIS” in the subject line.

Accompanying Documents
The accompanying documents—the 2025 Plan Year QIS Implementation Plan form, Progress
Report form, and Modification Summary Supplement form (QIS forms)—are the forms for
issuers to use to submit a QIS as part of their QHP application. These documents can be found
on the Centers for Medicare & Medicaid Services (CMS) Health Insurance MQI website (link in
the table below).
Website Links
The following resources provide additional details related to QIS.
Website

Description

Link

CMS MQI website

This website provides resources related to CMS MQI
activities, including the Quality Rating System (QRS), the
QHP Enrollee Experience Survey (QHP Enrollee
Survey), QIS requirements, and patient safety standards.
As the central location for QIS resources, this website
contains the QIS forms and instructional documents
regarding QIS implementation and reporting, including
this document.

https://www.cms.gov/medicare
/quality/health-insurancemarketplace-initiatives

CMS QHP
Certification
website

This website provides issuers with detailed application
instructions, forms—including the QIS
forms―justifications, supporting documents, frequently
asked questions (FAQs), and tools to complete the
annual QHP application process.

https://www.qhpcertification.
cms.gov/s/QHP

The terms “Exchange” and “Marketplace” are synonymous. Marketplace is commonly used in consumer-facing
communications.
1

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Website

Description

Link

Health Care
Payment Learning
& Action Network
(LAN)

This website provides resources related to increasing the
adoption of value-based payments and alternative
payment models (APMs). The APM Framework White
Paper defines APM categories and subcategories. This
resource aligns to Element 16: Current Payment
Model(s) Description of the Implementation Plan form
and Element 15: Current Payment Model(s) Description
of the Progress Report form.

https://hcp-lan.org/

Registration for
Technical
Assistance Portal
(REGTAP)

This website serves as an information hub for CMS
technical assistance related to Exchange and Premium
Stabilization programs. Registered users can access the
library, training resources, and the inquiry tracking and
management system. Use keyword search “QIS” to
identify any QIS-related resources.

https://regtap.cms.gov/
(registration required)

State Exchange
Resource Virtual
Information
System (SERVIS) 2

This website serves as an information hub for CMS
technical assistance related to SBE requirements.
Registered state users can access relevant resources
organized by the Center for Consumer Information and
Insurance Oversight (CCIIO) State Marketplace and
Insurance Programs group (SMIPG).

https://portal.cms.gov/
(registration required)

Other Resources
•

•

The 2025 Final Letter to Issuers in the Federally-facilitated Exchanges (Final Letter to
Issuers) provides issuers seeking to offer QHPs, including stand-alone dental plans (SADPs),
in the FFEs, whether through the Individual Exchange or the Small Business Health Options
Program (SHOP), with operational and technical guidance to help them successfully
participate in those Exchanges during the 2025 Plan Year (PY).The approach for QHP
certification reviews for QIS reporting remains unchanged from the 2018 Letter to Issuers.
Please refer to the 2018 Letter to Issuers for more information.
The Patient Protection and Affordable Care Act ; Department of Health and Human Services
(HHS) Notice of Benefit and Payment Parameters for 2016 (2016 Payment Notice) 3 includes
implementation requirements for QHP quality improvement strategies beginning with the
2016 Plan Year.
The Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment
Parameters for 2023 (2023 Payment Notice) 4 includes an update to the QIS standards to
require QHP issuers to address health and health care disparities as a specific topic area
within one of their quality improvement strategies beginning in calendar year 2023 for the
2024 Plan Year.

To access any SERVIS links, an issuer must first log in to CMS Enterprise Identity Management (EIDM), then log
in to SERVIS and click the link.
3
Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2016; Final Rule,
80 FR 10750 at 10876 (February 27, 2015) (45 CFR § 156.1130).
4
Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2023; Final Rule,
87 FR 27208 at 27341 (May 6, 2022) (45 CFR § 156.1130).
2

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Quality Improvement Strategy Technical Guidance and User Guide for the 2024 Plan Year

Document Purpose and Scope

The Quality Improvement Strategy: Technical Guidance and User Guide for the 2025 Plan Year
(2025 QIS Guidance) provides: (1) Technical Guidance, including comprehensive background
information about the QIS requirements, and (2) a User Guide with step-by-step instructions for
how to comply with the QIS requirements for the 2025 Plan Year. This document is organized
into two volumes:
•
•

Volume I: QIS Technical Guidance for the 2025 Plan Year (QIS Technical Guidance) and
Volume II: QIS User Guide for the 2025 Plan Year (QIS User Guide).

Issuers should refer to the updated QIS Technical Guidance and the QIS User Guide for the
upcoming plan year on an annual basis, regardless of QIS submission type, as CMS updates both
volumes yearly, as may be necessary, to reflect any relevant changes. Issuers should also adhere
to the CCIIO QHP Certification Process (reflected in the Final Letter to Issuers), which may
evolve on an annual basis.

2.1

Section Guide

Volume I: QIS Technical Guidance for the 2025 Plan Year
The QIS Technical Guidance provides information on the QIS participation criteria and reporting
requirements for all issuers offering or seeking to offer QHP coverage through an Exchange and
on the evaluation methodology for the FFEs, including FFEs where states perform plan
management, to review issuers’ QIS submissions.
Where applicable, the section descriptions highlight key differences between the QIS Technical
Guidance for the 2025 Plan Year and the previous versions of the guidance.
This guidance will address changes to the QIS forms for the 2025 Plan Year, including updated
guidelines regarding use of the Modification Summary Supplement form. Throughout this
document, unless otherwise noted, references to an FFE or FFEs refer to both FFEs and FFEs
where the state performs plan management. Similarly, references to an SBE or SBEs refer to
both SBEs and SBEs on the Federal Platform (SBE-FPs), unless otherwise noted.
The requirements outlined in this document are based on statute and CMS regulations, including
the Patient Protection and Affordable Care Act (PPACA), the 2016 Payment Notice, and the
2023 Payment Notice.
The Technical Guidance includes the following sections, which provide:
•
•
•
•
•
•

Background on the QIS,
An overview of the QIS Technical Guidance,
The QIS timeline for the 2025 Plan Year,
Exchange oversight responsibilities,
The QIS requirements, and
The QIS evaluation process and methodology.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Key Differences Between the 2024 QIS Technical Guidance
and 2025 QIS Technical Guidance
Section 5.3.2: Changing a QIS – Beginning with the 2025 Plan Year QHP Application
Period, issuers who want to make changes to their QIS but have already submitted two
Modification Summary Supplement forms to change the same QIS must submit a
Progress Report Closeout form to discontinue that QIS and submit a new
Implementation Plan form to create a new QIS.
Volume II: QIS User Guide for the 2025 Plan Year
The QIS User Guide provides issuers offering coverage in an FFE with directions to meet the
QIS requirements for the 2025 Plan Year. The User Guide provides procedural, step-by-step
instructions for issuers on how to access, complete, and submit the Implementation Plan form,
Progress Report form, and Modification Summary Supplement form to CMS during the PY2025
QHP Application Period. 5
The QIS User Guide covers each aspect of the QIS application and submission process and
includes the following sections, which provide:
•
•
•
•
•
•

An introduction to the User Guide,
Instructions for completing the Implementation Plan form,
Instructions for completing the Progress Report form,
Instructions for completing the Modification Summary Supplement form,
Information on how and when to submit the Implementation Plan form, Progress Report
form, and/or Modification Summary Supplement form, and
Instructions on what steps issuers may need to take after their QIS submissions have been
evaluated.

The key differences between the 2024 QIS User Guide and the 2025 QIS User Guide are
described below.
Key Differences Between the 2024 QIS User Guide and the 2025 QIS User Guide
Section 5: Complete the QIS Modification Summary Supplement Form – Information
has been added to this section on how to use the Modification Summary Supplement
form. Additional information is provided regarding situations when an issuer will need
to discontinue a QIS and create a new QIS to make additional changes to an existing
QIS.

The PY2025 QHP Application Period occurs in calendar year 2024. See the 2025 Plan Year QHP Data Submission
Key Dates Timeline available at: https://www.qhpcertification.cms.gov/s/Timeline. The 2025 Plan Year occurs in
calendar year 2025.
5

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Volume I. QIS Technical Guidance for the 2025 Plan Year

pg. 5

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Background

An issuer participating in an Exchange for two or more consecutive years must implement and
report on a QIS, in accordance with section 1311(g) of the PPACA, entitled “Rewarding Quality
Through Market-Based Incentives.” 6 A QIS should incentivize quality by tying payments to
measures of performance when providers meet specific quality indicators or enrollees make
certain choices or exhibit behaviors associated with improved health.
The QIS requirements apply to all issuers offering QHPs through an Exchange, whether through
the Individual Exchange or through the SHOP. Throughout this document, references to
“issuers” refer to issuers offering or applying to offer QHPs in an Exchange.
The issuer’s QIS must cover all of its QHPs offered through an Exchange that meet the
participation criteria described in Section 5.1 of this Technical Guidance. An issuer has the
option of implementing one QIS that covers all eligible health plans and product types or
implementing multiple quality improvement strategies to cover all eligible health plans and
product types.
All issuers must comply with the following requirements:
(1) Implement a QIS, described as a payment structure that provides increased
reimbursement or other market-based incentives for improving health outcomes of plan
enrollees.
(2) Implement a QIS that includes at least one of the following:
i. Activities to improve health outcomes,
ii. Activities to prevent hospital readmissions,
iii. Activities to improve patient safety and reduce medical errors,
iv. Activities for wellness and health promotion.
(3) Implement at least one QIS that includes activities to reduce health and health care
disparities.
(4) Adhere to guidelines, including the QIS Technical Guidance and QIS User Guide,
established by HHS in consultation with experts in health care quality and interested
parties.
(5) Report on progress implementing the QIS to the applicable Exchange on a periodic basis.
CMS envisions issuers aligning their quality improvement activities with the quality priorities
identified in the Meaningful Measures Framework. 7 The QIS statutory requirements require the
use of market-based incentives to improve the quality and value of health care and services,
specifically, for Exchange enrollees. Section 1311(g) specifies two market-based incentive types
that issuers may include in their quality improvement strategies: (1) increased reimbursement or

Section 1311(c)(1)(E) of the PPACA, 45 CFR §§ 156.200(b) and 156.1130.
The Meaningful Measures quality priorities can be found here: https://www.cms.gov/Medicare/Quality-InitiativesPatient-Assessment-Instruments/QualityInitiativesGenInfo/MMF/General-info-Sub-Page.html.
6
7

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

(2) other incentives. These incentive types are defined below; additional examples are provided
in Appendix E.
(1) Increased Reimbursement
o Providers receive an increased or higher level of payment and/or a bonus payment
based on whether they meet certain quality performance targets. If providers do not
meet all of the performance targets, they receive only a portion of the maximum
payment they are eligible to receive.
(2) Other Incentives
o “Other Provider Incentives” is defined as the provision of provider resources, such as
physician practice transformation and clinical support for meeting certain quality
performance targets.
o “Enrollee Financial Incentives” is defined as a monetary reduction of what an
enrollee pays for premiums and other out-of-pocket costs (e.g., co-payment,
co-insurance) as a result of the consumer making certain choices or exhibiting
behaviors associated with improved health (e.g., seeking preventive services, seeking
“high-value” providers, accessing nutritional counseling). 8
All QIS activities must be linked to an incentive. An issuer may choose to implement a provider
market-based incentive, an enrollee market-based incentive, or both. Population- or communitybased activities may meet the QIS requirements if they are linked to an incentive. While
incentives may be monetary in nature, they are not required to be. The incentive must provide
additional value to the recipient, whether that be through an additional service or a financial
resource. See Exhibit 1 for examples of activities cited in the PPACA that may be included in
issuers’ quality improvement strategies.
Exhibit 1: Examples of QIS Activities Cited in the Patient Protection and Affordable Care Act 9
QIS Topic Area

Examples of QIS Activities

Improve Health Outcomes







Quality reporting
Effective case management
Care coordination
Chronic disease management
Medication and care compliance initiatives

Prevent Hospital
Readmissions



Improve Patient Safety and
Reduce Medical Errors

Comprehensive program for hospital discharge that includes:
- Patient-centered education and counseling
- Comprehensive discharge planning
- Post discharge reinforcement by an appropriate health care professional





Appropriate use of best clinical practices
Evidence-based medicine
Health information technology

Any enrollee financial incentives used as part of an issuer’s QIS must comply with other applicable federal and
state requirements, including those applicable to premiums and rating, plan design, and actuarial value. For example,
wellness program incentives must comply with the federal wellness program regulations at 26 CFR § 54.9802-1(f),
29 CFR § 2590.702(f), and 45 CFR § 146.121(f).
9
The wellness and health promotion activities are cited in Section 2717(b) of the Public Health Service Act. All
other activities are cited in Section 1311(g)(1) of the PPACA.
8

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
QIS Topic Area

Examples of QIS Activities

Implement Wellness and
Health Promotion Activities







Smoking cessation
Weight management
Stress management
Healthy lifestyle support
Diabetes prevention

Reduce Health and Health
Care Disparities







Language services
Community outreach
Cultural competency trainings
Social needs-sensitive self-management recommendations
Expanded collection, reporting, and analysis of standardized demographic
and social determinants of health (SDOH) data

All Exchanges are required 10 to evaluate issuers’ QIS submissions, and issuers must submit
separate QIS submissions by state. In addition, this review process includes the following
activities:
CMS will evaluate the QIS submissions for issuers applying to offer QHPs in an FFE.
In FFEs where the state performs plan management, issuers applying to offer QHPs will
undergo a joint review of their QIS submissions by the state and CMS, with final
determination being made by CMS.
SBEs will evaluate the QIS submissions of the issuers applying to offer QHPs in their state’s
Exchange. SBEs have the flexibility to establish the timeline, reporting form, validation of
data, and other requirements related to annual submission of QIS data by the issuers
participating in their respective Exchanges. However, SBEs must comply with the federal
minimum reporting requirements.
For the PY2025 QHP Application Period, SBEs must, at a minimum, require issuers to
submit QIS information in accordance with the elements and criteria included in the QIS
forms. SBEs are encouraged to use the reporting manner and frequency requirements
established by the FFEs to minimize the burden of reporting. However, SBEs may establish
their own reporting forms, evaluation methodologies, and reporting manner and frequency
requirements.

•
•
•

•

Technical Guidance Overview

The goal of QIS implementation is to improve the quality and value of care delivered to
Exchange enrollees through strategies that provide for increased reimbursement or other marketbased incentives that reward quality health care. Through their implementation, QIS activities
will help to strengthen system-wide efforts to improve health care quality and health outcomes.
To achieve this goal, CMS will do the following:
•
•
•
10
11

Operationalize the requirements in the statute. 11
Align the statutory requirements with other quality improvement programs. As applicable,
the QIS will align with the QRS, the QHP Enrollee Survey, and the Medicare Advantage
Quality Improvement Program/Chronic Care Improvement Program.
Offer flexibility to encourage issuer innovation and to promote a culture of continuous
quality improvement. This flexibility includes allowing issuers to use existing quality
45 CFR § 155.200(d).
Section 1311(c)(1)(E) of the PPACA, 45 CFR §§ 156.200(b) and 156.1130.
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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

•
•

improvement strategies that are in place for non-Exchange enrollee populations and/or
implemented in response to such initiatives as the Medicare Shared Savings Program or other
Accountable Care models if the existing strategy is relevant to the issuer’s Exchange
population and meets the QIS requirements.
Allow for flexibility for state implementation, meaning QIS implementation will establish
minimum requirements upon which SBE states, if desired, can build additional program
requirements in accordance with their local priorities.
Develop requirements in a public and transparent manner.

Section 1311(c)(1)(E) of the PPACA and the implementing regulation require an issuer
participating in an Exchange for two or more consecutive years to implement and report on a
QIS. There are two ways an issuer may accomplish this: (1) implement one QIS that applies to
all of its eligible product types and QHPs in a given Exchange; or (2) implement more than one
QIS, if having one QIS does not address all of its eligible product types and QHPs. All of the
issuer’s QHPs offered through an Exchange that meet the participation criteria described in
Section 5.1 of the Technical Guidance (referred to as “eligible QHPs”) must be covered by a
QIS.
Issuers have the benefit of two years of experience offering coverage through an Exchange to
understand and build quality performance data on their Exchange enrollees before being required
to submit a QIS. Issuers must define the health outcome needs of their enrollees (e.g., if an issuer
has a large proportion of diabetic enrollees, they may elect to incentivize enrollees to maintain
regular doctor visits for diabetes care, and/or incentivize physicians to focus on improving
diabetic patient outcomes).
A QIS does not have to address the needs of all enrollees in a given QHP that is offered through
an Exchange. Based on the rationale an issuer provides in its QIS submission, a QIS may address
a sub-population of a QHP’s enrollee population, depending on the sub-population’s identified
needs.
An issuer that offered an eligible QHP through an Exchange in calendar year 2022 and 2023 and
continues operating in the Exchange in calendar year 2024 must make at least one initial
Implementation Plan form submission to the applicable Exchange in calendar year 2024 for the
2025 Plan Year.
An issuer that submitted an Implementation Plan form or Progress Report form for the 2024 Plan
Year must submit a Progress Report form for the 2025 Plan Year.
Each year, CMS posts the QIS Issuer List for the upcoming plan year on the CMS MQI website.
The QIS Issuer List identifies issuers that meet the QIS participation criteria for the upcoming
plan year and that are consequently required to submit at least one Implementation Plan form
and/or Progress Report form as part of their QHP applications. These issuers are required to
either: (a) implement a new QIS beginning no later than January of the following year, or (b)
report progress on an existing QIS. The QIS Issuer List identifies issuers operating in FFEs that
meet the QIS participation criteria. Issuers operating in SBEs are not included on the QIS
Issuer List and should contact their Exchange for participation and submission requirements.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

CMS provides issuers an opportunity to review the QIS Issuer List and provide any
updates to CMS before the Issuer List is finalized and posted.
1. CMS will provide a draft QIS Issuer List in the spring of 2024.
2. FFE issuers will be informed via notifications from the Health Insurance Oversight
System (HIOS) Marketplace Quality Module (MQM) when the draft QIS Issuer List is
available on the MQI website. 12
3. Issuers will be able to review the draft Issuer List to verify their information and may
communicate any discrepancies to CMS by emailing [email protected] with
“QIS Issuer List” in the subject line.
The QIS forms can be accessed via the MQI website. All issuers that meet the QIS participation
criteria, regardless of submission type, must use the updated 2025 QIS forms.
The QIS elements and criteria in the QIS forms are described in detail in the QIS User Guide for
the 2025 Plan Year. Each element has associated criteria that describe the type of information
issuers must provide. A more detailed explanation of the organization of the 2025 QIS forms is
provided in Section 5.2.1 of this Technical Guidance.

QIS Timeline for the 2025 Plan Year

Issuers applying for QHP certification in the FFEs will submit QIS forms during the annual QHP
Application Period for the 2025 Plan Year. They should refer to the CMS final bulletin titled
Qualified Health Plan (QHP) Data Submission and Certification Timeline for Plan Year 2025 for
the finalized QHP data submission and certification timeline. Issuers operating in SBEs should
refer to their Exchanges regarding specific time frames for the 2025 Plan Year.

Exchange Oversight Responsibilities

Exchanges are responsible for QHP certification and oversight of compliance with certification
standards by QHP issuers operating in their respective Exchanges. All Exchanges are responsible
for evaluating issuers’ QIS submissions as a condition of QHP certification for the 2025 Plan
Year.

4.1

Federally-facilitated Exchanges

FFE states will follow the QHP Certification Process, which is outlined in the 2025 Final Letter
to Issuers, as it pertains to the QIS requirements.
FFE states performing plan management will receive completed QIS forms directly from issuers
offering coverage through their states, as part of the issuers’ QHP applications, via the System
for Electronic Rates and Forms Filing (SERFF). FFE states performing plan management must
use the federal QIS evaluation methodology to evaluate the QIS submissions of issuers offering
coverage through their respective Exchanges; however, issuers should contact the states for

More information about the HIOS MQM system can be found in the HIOS MQM Quick Reference Guide.
pg. 10

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

additional details. CMS will also review the QIS submissions of issuers offering coverage in FFE
states performing plan management.
CMS may conduct targeted compliance reviews under 45 CFR § 156.715 to examine QHP issuer
compliance with the federal reporting requirements. Compliance with the QIS data submission
and reporting requirements may be included as part of a more general compliance review of an
issuer participating in an FFE. For example, as part of compliance reviews, issuers may be
required to provide a list of HIOS Standard Component IDs (SCIDs) covered by their quality
improvement strategies to verify that all eligible QHPs are covered. CMS intends to coordinate
with state regulators, the applicable state entities for FFE states performing plan management,
and SBEs, when appropriate, to avoid duplication of efforts for these compliance reviews.

4.2

State-based Exchanges

The QIS requirements are designed to provide SBEs with flexibility to establish the timeline,
reporting form, validation, and other requirements related to annual submission of QIS data by
the issuers that participate in their respective Exchanges. FFE standards provide the minimum
requirements as a foundation for SBEs. SBEs that establish and implement such standards and
other requirements support compliance with 45 CFR § 155.200(d), which requires Exchanges to
evaluate and oversee implementation of each QIS submitted by issuers operating in their states
(among other issuer quality initiatives for coverage offered through the Exchanges).
SBEs will evaluate the QIS submissions of the issuers applying to offer QHPs in their state’s
Exchange. SBEs must ensure issuers that meet the QIS participation criteria and operate in their
respective Exchanges comply with the federal minimum reporting requirements, which include
the QIS requirements outlined in the QIS Technical Guidance and QIS User Guide, and the
information collected in the QIS forms. SBEs are encouraged to use the reporting manner and
frequency requirements established by CMS for the FFEs to minimize the burden of reporting.
Issuers operating in SBEs should consult these states for information about how to comply with
the states’ QIS requirements as SBEs may have established their own reporting manner,
frequency requirements, and additional reporting requirements.

QIS Requirements

This section outlines the requirements for determining which issuers will be included on the
QIS Issuer List and, consequently, must submit an Implementation Plan form and/or Progress
Report form to the applicable Exchange (see Section 5.3 for additional QIS forms submission
guidance for the 2025 Plan Year). Information on the QIS participation criteria, calculating the
minimum enrollment threshold, and the QIS forms is provided below.

5.1

Participation Criteria

Issuers applying for QHP certification in the Exchanges for the 2025 Plan Year that meet the QIS
participation criteria are expected to submit one or more of the QIS forms in calendar year 2024

pg. 11

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

to either: (a) implement a new QIS beginning no later than January 1, 2025 or (b) provide a
progress update on an existing QIS. 13

5.1.1

Participation Criteria for Implementing a QIS

An issuer must implement a new QIS by submitting an Implementation Plan form to an
Exchange for the 2025 Plan Year if the following conditions apply:
•

An issuer offered coverage through an Exchange in calendar year 2022 and 2023. The
QIS reporting requirements apply to an issuer that has been operating in an Exchange for two
consecutive years and will continue operating in the Exchange in calendar year 2024,
regardless of whether its QHPs have changed during that time.
o This phased-in approach gives the issuer the necessary time to understand the
populations enrolling in a QHP offered through the Exchange and to build quality
performance data on its respective QHP enrollees.
o If an issuer offered coverage in calendar year 2023 and 2024 (but not in 2022), the
issuer would not need to submit a QIS until calendar year 2025 for the 2026 Plan
Year.
o If an issuer is not continuing to offer coverage through an Exchange in the 2025 Plan
Year, it does not need to submit a QIS.

•

An issuer provides family and/or adult-only medical coverage. The QIS (or more than
one QIS) should cover all eligible QHPs. Eligible QHPs are QHPs offered through the
Exchange at all levels of coverage (Bronze, Expanded Bronze, Silver, Gold, Platinum, and
Catastrophic) for the following product types: health maintenance organizations (HMOs),
preferred provider organizations (PPOs), point of service (POS) plans, and exclusive
provider organizations (EPOs). At this time, the QIS requirements do not apply to child-only
plans, SADPs, indemnity plans, or Basic Health Program (BHP) plans. The QIS requirements
include QHPs that are compatible with Health Savings Accounts (HSAs) (also known as
HSA-eligible plans). The inclusion of HSA-eligible plans is consistent with the QRS
requirements and increases QIS participation overall by ensuring issuers that meet the other
QIS participation criteria, but offer only HSA-eligible plans, are required to implement a
QIS. Issuers are therefore expected to include HSA-eligible plans that meet the other QIS
participation criteria in their 2025 Plan Year QIS submissions.

Issuers are permitted to use a QIS they are already implementing for an Exchange or another product line, as long
as it meets the QIS elements and criteria and is relevant to their Exchange population.
13

pg. 12

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

•

5.2

An issuer meets the QIS minimum
enrollment threshold. An issuer that had
more than 500 enrollees within a product type
per state as of July 1 of the prior year meets
the minimum enrollment threshold. An issuer
that changed product types will continue to
meet the minimum enrollment threshold when
the issuer: (a) crosswalks enrollees from the
old product type to a different one, and (b)
still has more than 500 enrollees in the new
product type. An issuer that meets these
requirements will be required to submit a QIS
that covers all eligible QHPs within that
product type. Enrollees who purchased
insurance outside the Exchange
(off-Exchange) should not be included in the
minimum enrollment calculation.

How Many QIS Implementation
Plans Should an Issuer Submit?
If an issuer uses the same QIS across
multiple Exchanges, the issuer will need to
submit a separate Implementation Plan form
to each Exchange in which it offers eligible
QHPs.
• An issuer must implement at least one
QIS per Exchange in which it offers
eligible QHPs.
• An issuer may implement multiple quality
improvement strategies within the same
Exchange if it has different strategies for
different eligible product types and/or
QHPs within the same Exchange.
• Each eligible QHP must be included in a
QIS.

Calculating the Minimum Enrollment Threshold

To determine whether a product type and, therefore, an issuer meets the minimum threshold,
issuers must include enrollees in eligible QHPs. When determining which enrollees to include,
issuers must consider the following requirements:
•
•

•

Issuers should include only enrollees in QHPs offered through an Exchange (on-Exchange).
Enrollees who purchased insurance outside the Exchange (off-Exchange) are not included in
the minimum enrollment calculation.
Issuers should include all enrollees in QHPs that provide family and/or adult-only medical
coverage. Enrollees in HSA-eligible plans should also be included in the minimum
enrollment calculation. Enrollees in child-only plans, SADPs, indemnity plans, or BHP plans
should not be included in the minimum enrollment calculation.
If issuers offer QHPs of the same product type in both the Individual Exchange and SHOP
within a state, they must combine the enrollee totals from both the Individual Exchange and
SHOP Exchange.

Example: A fictional issuer that offered QHPs (all offering family medical coverage) through
the Exchanges in calendar years 2022 and 2023, and continued offering coverage in calendar
year 2024, in three states—West Virginia (WV), Florida (FL), and North Carolina (NC)—has
applied for certification of those QHPs in calendar year 2024 for the 2025 Plan Year. Exhibit 2
shows the characteristics and enrollment size of the issuer’s product types in each state. In
accordance with the participation criteria defined above, this issuer must develop and submit a
QIS Implementation Plan to the Exchange for only West Virginia and Florida. The issuer does
not need to submit a QIS Implementation Plan in North Carolina because it did not have a
sufficient number of enrollees within each product type as of July 1, 2023.

pg. 13

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Exhibit 2: Example Issuer Submissions Assessed Against QIS Participation Criteria
Number of Enrollees in the Product Type
as of July 1, 2023 (Total and per
Individual Exchange vs. SHOP)

Issuer
Should
Submit QIS

All Product Types and
Applicable QHPs Need To
Be Covered by a QIS

ABC issuer – WV

HMO: 505 (505 individual, 0 SHOP)
PPO: 600 (500 individual, 100 SHOP)

Yes

ABC issuer – FL

HMO: 601 (501 individual, 100 SHOP)
PPO: 400 (300 individual, 100 SHOP)

Yes

No, only the HMO and
applicable QHPs must be
covered by a QIS

ABC issuer – NC

HMO: 300 (200 individual, 100 SHOP)
PPO: 400 (300 individual, 100 SHOP)

Reporting Unit

5.2.1

Participation Criteria for Progress Reporting

For Progress Report submissions for an existing QIS, CMS will reassess an issuer’s product type
enrollment after two consecutive Progress Report submissions. As such, an issuer must submit
two consecutive years of Progress Report forms if it is continuing a QIS, regardless of whether
the issuer’s product type(s) continues to meet the minimum enrollment threshold, as shown in
Exhibit 3.
Exhibit 3: Application of the Minimum Enrollment Threshold to Progress Reporting

Calendar Year of
Implementation
Plan Submission

Implementation
Plan (Plan Year)
if Minimum
Enrollment
Threshold Met

Initial Progress
Report
(Plan Years)

Calendar Year of
Minimum
Enrollment
Reassessment

Subsequent
Progress Report
(Plan Years) if
Minimum
Enrollment
Threshold Is Met 14

2019

2020

2022 and 2023

2023

2024 and 2025

2020 15

2021

2022 and 2023

2023

2024 and 2025

2021

2022

2023 and 2024

2024

2025 and 2026

2022

2023

2024 and 2025

2025

2026 and 2027

2023

2024

2025 and 2026

2026

2027 and 2028

2024

2025

2026 and 2027

2027

2028 and 2029

An issuer may discontinue Progress Report submissions if a QIS for its product type(s) no longer
meets the minimum enrollment threshold prior to the third consecutive year of submitting a
Progress Report form. If the issuer’s product type(s) meets the minimum enrollment threshold
for the third consecutive year of submitting a Progress Report form, the issuer must submit the
Progress Report form for an additional two consecutive years.

If an issuer’s product type does not meet the minimum enrollment threshold when reassessed, the issuer would no
longer be required to report on a QIS for that product. Once the issuer meets all the QIS participation criteria again,
the issuer would restart its QIS reporting by submitting at least one QIS Implementation Plan for that product.
15
There were no QIS submissions in calendar year 2020 for the 2021 Plan Year due to the suspension of data
collection for the 2021 Plan Year. See COVID-19 and Suspension of Certain Activities Related to the Health
Insurance Exchange Quality Rating System, QHP Enrollee Experience Survey (QHP Enrollee Survey) and Quality
Improvement Strategy Programs memo, available at: https://www.cms.gov/files/document/covid-qrs-andmarketplace-quality-initiatives-memo-final.pdf.
14

pg. 14

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

After the submission of those two additional Progress Report forms, there would be another
reassessment of minimum enrollment size prior to the sixth consecutive year of submission of
the Progress Report form. This reassessment would continue after every two consecutive years of
submission of Progress Report forms.
Issuers that continue to meet the QIS participation criteria will be included on the QIS Issuer List
and required to continue QIS reporting. These issuers’ product type enrollment would then be
reevaluated to see if these issuers still meet the minimum enrollment threshold after two more
consecutive years of Progress Report submissions. Instructions for how to calculate the
minimum enrollment threshold are provided in Section 5.2. 16

5.3

QIS Implementation Plan, Progress Report, and Modification Summary
Supplement Forms

The QIS forms are separated into three component parts: the Implementation Plan form, the
Progress Report form, and the Modification Summary Supplement form.
•

Issuers submitting a new QIS complete must submit the Implementation Plan form only,
while issuers continuing a QIS must submit the Progress Report form only.

•

Issuers discontinuing a QIS and implementing a new QIS must submit the
Implementation Plan form and Progress Report Closeout form.

•

Issuers modifying components of an existing QIS for the upcoming year must submit the
Modification Summary Supplement form and the Progress Report form. 17

See Exhibit 16 in the QIS User Guide for a decision tree to determine the appropriate form(s) for
submission.
Issuers applying for QHP certification in FFE states for the 2025 Plan Year and that meet the
QIS participation criteria are expected to submit a QIS form in calendar year 2024 to either:
(a) implement a new QIS beginning no later than January 1, 2025, (b) provide a progress update
on an existing QIS, or (c) modify an existing QIS. 18

5.3.1

QIS Forms Purpose and Use

The Implementation Plan form is prospective, detailing the components of the QIS an issuer
plans to implement on January 1 of the upcoming plan year.

Minimum enrollment is assessed prior to the third year in which an issuer would be reporting on progress on their
QIS. Minimum enrollment is also assessed prior to the sixth year in which an issuer would be reporting on progress
for a particular QIS. If an issuer closes out a QIS prior to the third year of progress reporting, the minimum
enrollment will be assessed prior to the third year of progress reporting on the new QIS.
17
Beginning with the 2025 Plan Year QHP Application Period, issuers who want to make changes to an existing
QIS but have already submitted two Modification Summary Supplement forms to change the same QIS must submit
a Progress Report Closeout form to discontinue that QIS and submit a new Implementation Plan form to establish a
new QIS.
18
Issuers are permitted to use a strategy they are already implementing for the Exchange or another product line, as
long as the strategy meets the QIS elements and criteria and is relevant to the issuer’s Exchange population.
16

pg. 15

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

The Progress Report form is a retrospective look at the progress each issuer has made on the QIS
since the last submission. This form is also used to
Commonly Used QIS Terms
discontinue and close out an existing QIS.
The Modification Summary Supplement form is
also prospective, describing modifications to
components of an existing QIS related to topic
areas, product types, goals, activities, measures, or
performance targets that the issuer plans to make in
the upcoming plan year.
All issuers, regardless of submission type, must use
the updated QIS forms.

• QIS requirements: The information
issuers are required to submit for
evaluation by an Exchange
• Elements: Identifying and descriptive
information issuers use to complete the
QIS forms
• Criteria: Descriptions of the type of
information issuers must provide and the
rules an Exchange uses to evaluate
whether an issuer’s QIS fulfills the QIS
requirements

The goal of the QIS forms is to collect information
from issuers that demonstrates compliance with section 1311(c)(1)(E) of the PPACA. This
information also facilitates CMS’ understanding of the issuer’s payment structure framework
that provides increased reimbursement or other market-based incentives for the implementation
of activities related to the topics specified in section 1311(g) of the PPACA.
CMS anticipates the display of a subset of this information to promote transparency and will
provide additional details in the future. It is not intended that the public display of payment
structure information will include information considered confidential or proprietary.
The QIS forms provide a structure for an issuer to show that their QIS includes all the necessary
components and adequately addresses the QIS criteria. By submitting information in response to
all the elements and meeting the criteria, an issuer will demonstrate they have examined their
enrollee population and have designed a QIS that provides market-based incentives to drive
quality improvement and improved health outcomes.
Issuers use the QIS forms to submit an Implementation Plan, Progress Report, and Modification
Summary Supplement, as necessary, to the relevant Exchange. CMS has updated the submission
type options to reflect the new separate forms and submission scenarios. Issuers should
determine which forms are applicable for their submission scenario by reviewing the information
in the QIS Issuer List posted to the MQI website. Issuers should also review the decision tree in
Exhibit 16 in the QIS User Guide to help determine the appropriate form(s) for submission.
Once issuers have determined which form(s) they need to submit for the 2025 Plan Year, they
should follow the applicable instructions throughout this document based on their determination
of which forms are appropriate for that year. During the 2025 QHP Application Period, 19 issuers
that meet the QIS participation criteria, regardless of whether they are submitting an
Implementation Plan and/or Progress Report, will indicate in the form which of the following
types of information they are submitting:
•

Implementation Plan form options:
o New QIS After Discontinuing a QIS Submitted During a Prior Qualified Health Plan
(QHP) Application Period
The 2025 QHP Application Period occurs in calendar year 2024.
pg. 16

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

o New QIS with No Previous QIS Submission 20

Progress Report form options:
o Progress Report
o Progress Report Closeout

•

Modification Summary Supplement form option:
o Modification Summary Supplement

Issuers are strongly encouraged to leave a QIS in place for at least two years before modifying it
or developing a new QIS to allow time to determine whether the market-based incentives are
working as expected. Issuers submitting the Modification Summary Supplement form to
continue an existing QIS with modification(s) must also complete the Progress Report form to
report progress on the QIS.
The different types of QIS submissions are identified and described in Exhibit 4.
Exhibit 4: Type of QIS Submission
Type of QIS Submission

Description of Each Submission Type
Implementation Plan forms

New QIS After Discontinuing a
QIS Submitted During a Prior
QHP Application Period



New QIS with No Previous QIS
Submission



Select if the issuer:
- Changed its Market-Based Incentive sub-type (Element 21),
- Determines that its QIS is not having the expected impact,
- Determines that its QIS resulted in unintended consequences (e.g.,
negative impact on enrollee population), and/or
- Submitted two Modification Summary Supplement forms to change
the same QIS and intends to modify the existing QIS for a third time.
If selected, the issuer must discontinue its existing QIS by submitting a
Progress Report Closeout form and implement a new QIS by submitting a
new Implementation Plan form. 21
Select if the issuer:
- Did not submit a QIS during the PY2024 QHP Application Period and
meets the QIS requirements for the 2025 Plan Year specified in
Section 5.1.1, or
- Has a QIS on file and is submitting a new QIS that has not previously
been submitted to an Exchange (e.g., the new QIS differs from the
issuer’s prior QIS due to changes in market-based incentive or certain
other components that warrant a new QIS submission, as described
in Exhibit 5 below). The issuer will continue reporting on progress for
their existing QIS on file via the Progress Report form and will
implement a new QIS by submitting a new Implementation Plan form.

A “new QIS” is defined as either a QIS that has not been previously submitted to an Exchange OR a QIS that
differs from an issuer’s prior QIS due to changes in market-based incentives or certain other components that
warrant a new QIS submission.
21
Issuers may choose to discontinue a QIS for other reasons; however, as noted above, issuers are encouraged to
leave a QIS in place for at least two years.
20

pg. 17

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Type of QIS Submission

Description of Each Submission Type
Progress Report forms

Progress Report (i.e.,
Continuing a QIS Submitted
During a Prior QHP Application
Period and Making No Changes
or Making Changes that Do Not
Warrant a Modification)



Select if the issuer:
− Is continuing its current QIS and is reporting progress on it, and/or
− Is making one or more of the following changes to an existing QIS:
• Updates to issuer information,
• Updates to current payment model(s) description,
• Updates to data sources,
• Changes made in response to the prior year’s QIS evaluation
results not affecting Topic Areas, Goals, Activities, Product Types,
Performance Targets, or Measures, 22,23 and/or
• Other information not listed in the “Continuing QIS with
Modifications” in this exhibit.

Progress Report Closeout Form
(i.e., Discontinuing a QIS
Submitted During a Prior
Application Period)



Modification Summary Supplement forms
Continuing QIS with
Modifications (i.e., Continuing a
QIS Submitted During a Prior
Application Period and Making
Changes that Warrant a
Modification)



5.3.2

Select if the issuer is continuing and modifying an existing QIS to make
one or more of the following changes:
- Topic Area(s),
- Product Types,
- Goals,
- Activity(ies) That Will Be Conducted to Implement the QIS, and/or
- Measure(s) and Performance Target(s) to monitor QIS Progress.
These issuers must also complete the Progress Report form.

Changing a QIS

Some issuers submitting a Progress Report form may choose to make changes to their
Implementation Plan(s) submitted in a prior QHP application period. Certain changes can be
made year over year and captured in updates provided as part of the Progress Report, while some
changes necessitate completion of the Modification Summary Supplement form and others
require issuers to discontinue the QIS and implement a new QIS. Beginning during the PY2025
QHP Application Period, issuers who want to make changes to their QIS but have already
Changes made in response to the prior year’s QIS evaluation results not affecting Topic Areas, Goals, Activities,
Product Types, Performance Targets, or Measures do NOT warrant a modification to the QIS. Instead, in Element
17 of the Progress Report form, Summary of Progress, issuers must explain any changes made to address the prior
year’s QIS evaluation results that influenced the decision to modify the QIS. Element 17 has been separated into
criteria 17a, 17b, and 17c to make it easier for issuers to address the three parts of this question, as applicable. See
Section 4.1 of the QIS User Guide for further details.
23
Changes made in response to the prior year’s QIS evaluation results that affect Topic Areas, Goals, Activities,
Product Types, Performance Targets, or Measures do warrant a modification to the existing QIS submission and
trigger the requirement to submit a Modification Summary Supplement form. See Section 5 of the QIS User Guide
for more information.
24
Issuers may choose to discontinue a QIS for other reasons; however, as noted above, issuers are encouraged to
leave a QIS in place for at least two years.
22

pg. 18

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

submitted two Modification Summary Supplement forms to change the same QIS must
discontinue that QIS and submit a new Implementation Plan form to implement a new QIS that
reflects the additional desired changes. For each QIS that is modified by submission of the
Modification Summary Supplement form, CMS will keep the Modification Summary
Supplement form on file along with the relevant Implementation Plan form already on file and
any applicable Progress Report forms and amend the baseline data for the relevant strategy (as
applicable). Exhibit 5 provides information about the QIS submission requirements for and
implications of changing various components of the QIS.
Exhibit 5: Changing Components of a QIS
No Implications/Completion of
Progress Report form





Implementing a New QIS After
Discontinuing a QIS

Update issuer information,
Update current payment
model(s) description,
Update data sources, and/or
Update other information not
listed in the other columns in
this Exhibit.

5.3.3





Change QIS market-based
incentive sub-type,
The QIS is not having the
expected impact, and/or
The QIS results in negative
outcomes or unintended
consequences.

Completion of Modification
Summary Supplement Form







Change QIS topic areas,
Change QIS goals, 25
Change QIS activities,
Change QIS measures,
Change performance targets,
and/or
Change product types.

QIS Forms Structure

The sections of the QIS forms and their parts are listed in Exhibit 6.
Exhibit 6: QIS Forms – Sections and Parts
QIS Implementation Plan Form

QIS Progress Report Form

QIS Modification
Summary Supplement Form

QIS Submission Type Section

Part A: New QIS Submission

Part A: Progress Report or Closeout
QIS Submission

Part A: QIS Submission

Background Information Section

Part B: Issuer Information

QIS Implementation Plan Section

QIS Progress Report Section

QIS Modification Section

 Part D: QIS Summary
 Part E: QIS Requirements

Part C: Progress Report Summary

Part C: QIS Modification Summary




Part B: Issuer Information
Part C: Data Sources Used for
Problem Identification and
Monitoring Progress

New issuers that have not previously submitted a QIS to an Exchange, issuers that are submitting
a new QIS after discontinuing a QIS, or issuers that are submitting a new QIS that has not been
previously submitted to an Exchange while continuing to report on progress for an existing QIS,
will complete all sections of the Implementation Plan form. Issuers that are continuing an
existing QIS will complete and submit a Progress Report form for that strategy. Issuers that wish
to modify components of an existing QIS related to topic areas, product types, goals, activities,

In Part D of the Implementation Plan form, an issuer must summarize the overall goal or goals (no more than two)
of its QIS. The goal(s) must be linked to the issuer’s QIS topic area(s), as well as the quantitative performance
targets identified in Part E of the form in order to track the issuer’s progress toward meeting its QIS goals.

pg. 19

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

measures, or performance targets will complete the Modification Summary Supplement form 26
in addition to the Progress Report form.
Issuers must complete all required elements included in the QIS form that is being submitted. If
an issuer fails to provide responses to any criteria within any of the elements, CMS will ask the
issuer to complete the missing information and resubmit the form.
CMS will review the information submitted in Parts A, B, C, and D of the Implementation Plan
form, Parts A and B of the Progress Report form, and Parts A and B of the Modification
Summary Supplement form for completeness, but will not score these parts. Furthermore, CMS
will review the information submitted in Part E of the Implementation Plan form, Part C of the
Progress Report form, and Part C of the Modification Summary Supplement form for
completeness and will score these parts. (Refer to Section 6.3 for an explanation of QIS scoring.)
The QIS User Guide describes the elements found in each of the QIS forms. The list in
Appendix C summarizes each element by number and name and includes an explanation of each
element, the criteria upon which it will be evaluated, whether issuers’ responses are subject to
character limits, and whether changes to issuers’ responses constitute a modification or require
the issuer to discontinue the existing QIS and implement a new one.

QIS Completeness Assessment and Evaluation

On an annual basis, issuers must meet the QIS requirements as part of the QHP Certification
Process. Submitted QIS forms go through a series of reviews and communications referred to as
the Completeness Assessment and Evaluation process. During the QHP Application Period,
CMS 27 will assess QIS submissions for completeness and, following the conclusion of the QHP
Application Period, CMS will evaluate the completed QIS forms to determine if they meet the
QIS requirements. CMS will communicate QIS completeness assessment and evaluation results
(e.g., identified deficiencies, potential concerns, and recommended actions to issuers). Exhibit 7
details the activities involved in each stage of the QIS Completeness Assessment and Evaluation
process. CMS assesses and evaluates each issuer’s QIS submission to determine whether the
issuer’s QIS meets the applicable requirements according to the applicable plan year’s QHP
Application and Certification Process review stages and timeline. 28 Exhibit 7 provides a highlevel overview of the Completeness Assessment and Evaluation QIS submissions will undergo.

See Section 5.3.1, Section 5.3.2, Exhibit 4, and Exhibit 5 of this Technical Guidance for information on the types
of updates to a QIS that do not trigger the requirement to submit the Modification Summary Supplement form.
27
45 CFR § 155.200(d) directs the Exchange to evaluate QIS submissions. For an FFE state, CMS will perform the
assessments and evaluations; however, for FFEs where the state performs plan management, the submission will be
jointly reviewed by CMS and the state, with the final determination made by CMS. For SBE states, the SBE will
perform the assessments and evaluations.
28
See the 2025 Plan Year QHP Data Submission Key Dates Timeline available at:
https://www.qhpcertification.cms.gov/s/Timeline.
26

pg. 20

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Exhibit 7: Completeness Assessment and Evaluation Process
COMPLETENESS
ASSESSMENT
COMPLETENESS

ASSESSMENT

REVIEW RESULTS

EVALUATION

REVIEW
RESULTS
REVIEW

RESULTS

• CMS checks that correct
• CMS alerts issuers to
• CMS evaluates
• CMS alerts issuers to
form(s) is(are) submitted
problems with
content of final
deficiencies
submissions
submissions against • Issuers address
• CMS checks that correct fields
QIS requirements
are completed
deficiencies through
• Issuers address problems
resubmissions
through resubmissions

In calendar year 2024, issuers submitting an Implementation Plan form will be required to
provide information on the entire Implementation Plan form as part of their QHP application for
the 2025 Plan Year, which includes the following sections 29:
•
•
•
•
•

Part A: New QIS Submission,
Part B: Issuer Information,
Part C: Data Sources Used for Problem Identification and Monitoring Progress,
Part D: QIS Summary, and
Part E: QIS Requirements.

Issuers that submitted quality improvement strategies as part of their 2024 Plan Year QHP
applications are required to report on progress during the PY2025 QHP Application Period.
These issuers do not need to complete an Implementation Plan form to report progress on those
strategies. 30 Issuers can also use the Progress Report form to report certain updates to an existing
QIS (e.g., to update issuer information, current payment model(s) descriptions and data
sources). 31 As part of their QHP application for the 2025 Plan Year, these issuers are only
required to submit information on the Progress Report form, which includes the following
sections:
•
•
•

Part A: Progress Report or Closeout QIS Submission (as applicable),
Part B: Issuer Information, and
Part C: QIS Progress Report Summary.

If issuers are modifying components of their existing QIS to make changes related to topic areas,
product types, goals, activities, measures, or performance targets, in addition to reporting on
progress via the Progress Report form, the issuer must submit the Modification Summary
Supplement form, which includes the following sections:
•
•
•

Part A: QIS Submission,
Part B: Issuer Information, and
Part C: QIS Modification Summary.

This includes issuers submitting a new QIS after discontinuing a QIS submitted during a prior QHP Application
Period, issuers submitting a new QIS in situations where there were no previous QIS submissions, and issuers
submitting a new QIS that has not been previously submitted to an Exchange, while also continuing to report on
progress for an existing QIS.
30
An exception to this general rule is for issuers that use the Progress Report form to discontinue and close out an
existing QIS who must also implement a new QIS by submitting a new Implementation Plan form. See Section
5.3.1, Section 5.3.2, Exhibit 4, and Exhibit 5 of this Technical Guidance for more information.
31
See Section 5.3.1, Section 5.3.2, Exhibit 4, and Exhibit 5 of this Technical Guidance for more information on the
different types of updates to an existing QIS and the different types of QIS submissions.
29

pg. 21

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Beginning with the 2025 Plan Year QHP Application Period, issuers who want to make changes
to an existing QIS but have already submitted two Modification Summary Supplement forms to
change the same QIS must submit a Progress Report Closeout form to discontinue that QIS and
submit a new Implementation Plan form to establish a new QIS.
For more information about how issuers determine which forms to submit, please see the
decision tree in Exhibit 16 in the QIS User Guide.

6.1

QIS Form Completeness Assessment Process

CMS assesses the completeness of QIS forms received during each submission window of the
QHP Application Period. Following the initial submission window, only issuers that meet the
QIS participation criteria but did not submit at least one QIS as required will receive notification
that they must submit a QIS.
Following the close of the rate review submission window, issuers whose submissions contain
blank fields and/or are missing required information will receive review results indicating which
fields were missing information. Issuers that are notified of missing information errors must
correct and resubmit their QIS form(s) 32 during the subsequent submission window within the
current QHP Application Period. CMS does not notify issuers if their QIS submissions are
assessed as fully complete.
Following the close of the final submission window, issuers that meet the QIS participation
criteria but did not submit at least one QIS as required will receive notification that they must
submit a QIS.
Exhibit 8 outlines the three scenarios in which an issuer will receive correction notifications and
the estimated communication time frame.
Exhibit 8: Corrections Timeline
QIS Submission Status

Corrections Timeline

Issuer meets the QIS participation criteria but did not
submit at least one QIS as required during the initial
submission window.

The issuer will receive notification following the initial
submission period.

Issuer meets the QIS participation criteria and
submitted at least one QIS during the initial
submission window, but the QIS form(s) is(are)
missing information.

The issuer will receive notification of required corrections
following the rate review period.

Issuer meets the QIS participation criteria but did not
submit at least one QIS as required during the
subsequent submission window in the current QHP
Application Period.

The issuer will receive notification following the final
submission period.

Once a QIS submission is deemed complete, CMS will then begin the evaluation process.

Note: Issuers must only resubmit the form for which the correction was identified.
pg. 22

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

6.2

QIS Evaluation Methodology

The QIS Evaluation Methodology reflects how CMS reviews and evaluates an issuer’s responses
to the elements and criteria of the QIS forms. CMS assesses the following inputs for
completeness: all fields in Elements 1–19 in Parts A–D of the Implementation Plan form,
Elements 1–15 in Parts A–B in the Progress Report form, and Elements 1–7 in Parts A−B in the
Modification Summary Supplement form.
For Part E of the Implementation Plan form and Part C of the Progress Report form, CMS uses a
“Partial-Credit plus Must-Pass” scoring approach. For Part C of the Modification Summary
Supplement form, CMS uses a “Must-Pass” scoring approach. All must-pass elements must have
all required criteria completed for an issuer to receive full credit. All non-must-pass elements
must have at least 50 percent of the required criteria completed for an issuer to receive full credit.
Further details on must-pass and other scored elements are provided in Section 6.3 of this
Technical Guidance.

6.3

Scoring the QIS Submission

CMS scores the QIS submission(s) at the element level and only for those elements included in
Part E of the Implementation Plan form, Part C of the Progress Report form, and Part C of the
Modification Summary Supplement form.

6.3.1

Implementation Plan Form (Part E) Scoring

All elements included in Part E of the Implementation Plan form are worth 1.00 point, regardless
of must-pass designation. An issuer receives a passing score for Part E if its submission: (1)
meets all of the criteria for the must-pass elements (i.e., receives 1.00 point for each must-pass
element), and (2) meets the minimum score threshold of 0.50 point (i.e., 50 percent) for each
scored element not designated as must-pass.
Elements 20−25 and 27 in Part E of the Implementation Plan form are must-pass, and there is no
partial credit offered for these seven elements. For must-pass elements, an issuer either receives
1.00 point (i.e., 100 percent) for meeting all criteria or receives 0.00 points (i.e., 0 percent) if any
criteria are not met.
Element 26 in Part E of the Implementation Plan form is also scored but is not must-pass. Issuers
may receive partial credit for this element based on the number of criteria they meet. See
Exhibit 9 for details on the scored elements that issuers are required to address in Part E of the
Implementation Plan form.

pg. 23

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Exhibit 9: Implementation Plan Form (Part E) Scored Elements by Type
Element Type
Must-Pass
Elements

Definition




Other Scored
Elements




Individual Elements

Issuer must meet all criteria within
an element to receive 1.00 point.
There is no partial credit; meeting
less than all criteria results in receipt
of 0.00 point.
Receiving 0.00 point on any mustpass element will result in issuer
receiving a correction notification.






Issuer may receive partial credit
based on how many criteria within
an element are met.
An issuer must receive at least 50
percent (0.50 point) on the element
to receive full credit.

Element 26: Timeline for Implementing the QIS




Element 21: Market-based Incentive Type(s)
Element 22: Topic Area Selection
Element 23: Rationale for QIS
Element 24: Activity(ies) That Will Be
Conducted to Implement the QIS
Element 25: Goal(s), Measure(s), and
Performance Target(s) to Monitor QIS
Progress
Element 27: Risk Assessment

CMS scores Element 26 (Timeline for Implementing the QIS) in Part E of the Implementation
Plan form, but this element is not must-pass. This element has two criteria, meaning issuers
receive full credit (1.00 point), even if their submission meets just one of the two criteria (i.e., 50
percent or 0.50 point). An issuer also receives full credit (i.e., 100 percent or 1.00 point) for
meeting both criteria. See Exhibit 10 for details.
Exhibit 10: Scoring Scale for Element 26 in the Implementation Plan Form (Part E)
Element 26,
Timeline for
Implementing
the QIS
(2 criteria)

6.3.2

# of Criteria
Met
Points
Awarded

100%

50%

Issuer meets
2 criteria

Issuer meets
1 criterion

Issuer meets
no criteria

1.00 point
awarded

0.00 point
awarded

Progress Report Form (Part C) Scoring

All elements included in Part C of the Progress Report form are worth 1.00 point, regardless of
must-pass designation. An issuer will receive a passing score for Part C of the Progress Report
form if it: (1) meets all of the criteria for the must-pass elements (i.e., receives 1.00 point for
each must-pass element); and (2) meets the minimum score thresholds of 0.50 point (i.e., 50
percent) for each scored element not designated as must-pass.
Elements 16 and 17 in Part C of the Progress Report form are must-pass, and there is no partial
credit offered for these elements. For must-pass elements, an issuer either receives 1.00 point
(i.e., 100 percent) for meeting all criteria or receives 0.00 points (i.e., 0 percent) if any criteria
are not met. Element 18 in Part C of the Progress Report form is scored but is not must-pass.
Issuers may receive partial credit for this element based on the number of criteria they meet. See
Exhibit 11 for details on the scored elements that issuers are required to address in Part C of the
Progress Report form.

pg. 24

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Exhibit 11: Progress Report Form (Part C) Scored Elements by Type
Element Type
Must-Pass
Elements

Definition




Other Scored
Elements




Individual Elements

Issuer must meet all criteria within an
element to receive 1.00 point.
There is no partial credit; meeting less
than all criteria results in receipt of 0.00
point.
Receiving 0.00 point on any must-pass
element will result in issuer receiving a
correction notification.



Issuer may receive partial credit based
on how many criteria within an element
are met.
Issuer must receive at least 50 percent
(0.50 point) on each of these elements
to receive full credit.

Element 18: Barriers and Mitigation Activities



Element 16: Analyze Progress Using
Baseline Data, as Documented in the
Implementation Plan
Element 17: Summary of Progress

CMS scores Element 18 (Barriers and Mitigation Activities) in Part C of the Progress Report
form, but this element is not must-pass. This element has two criteria, meaning issuers receive
full credit (1.00 point) even if their submission meets just one of the two criteria (i.e., 50 percent
or 0.50 point). An issuer receives full credit (i.e., 100 percent or 1.00 point) for meeting both
criteria. See Exhibit 12 for details.
Exhibit 12: Scoring Scale for Element 18 in the Progress Report Form (Part C)
Element 18,
Barriers and
Mitigation
Activities
(2 criteria)

6.3.3

# of Criteria
Met
Points
Awarded

100%

50%

Issuer meets
2 criteria

Issuer meets
1 criterion

Issuer meets
no criterion

1.00 point
awarded

0.00 point
awarded

Modification Summary Supplement Form (Part C) Scoring

There is one element in Part C of the Modification Summary Supplement form, it is scored, and
it is worth 1.00 point. An issuer will receive a passing score for Part C of the Modification
Supplement form if it meets all the criteria (i.e., receives 1.00 point).
Element 8 in Part C of the Modification Summary Supplement form is must-pass. An issuer
either receives 1.00 point (i.e., 100 percent) for meeting all criteria or receives 0.00 points (i.e., 0
percent) if any criteria are not met. See Exhibit 13 for details on the element that issuers are
required to address in Part C of the Modification Summary Supplement form.
Exhibit 13: Modification Summary Supplement Form (Part C) Scored Elements by Type
Element Type
Must-Pass
Elements

Definition




Individual Elements
Element 8: Modifying Topic Areas, Product Types,
Goals, Activities, and Measures or Associated
Performance Targets

pg. 25

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

6.3.4

QIS Forms Evaluation Process and Evaluation Outcomes

CMS will begin its evaluations of complete QIS submissions after the close of the PY2025 QHP
Application Period (in calendar year 2024). CMS will communicate evaluation results for QIS
submissions for the 2025 Plan Year to issuers in the late fall of 2024.
Based on the results captured in the QIS evaluation, CMS assigns an overall outcome of
“Meets,” “Interim Meets,” or “Does Not Meet” to each issuer’s QIS submission(s). Note, the
“Interim Meets” designation only applies to the Progress Report form. Exhibit 14 summarizes
these scoring designations. Issuers do not receive numerical scores; however, issuers are notified
if their QIS submissions were found incomplete (e.g., missing critical information) or were found
deficient. Issuers are expected to make corrections to the form(s) through resubmissions
following the release of the QIS evaluation results as directed by CMS.
At this time, CMS does not penalize issuers if they do not achieve the performance targets set out
in their QIS Implementation Plan forms; however, these issuers are required to track progress
and adjust their quality improvement strategy, as appropriate. 33
Exhibit 14: Scoring Designations
Score
Meets

Does Not Meet

Interim Meets

33
34

Conditions
An issuer receives a scoring designation of “Meets” for its Implementation Plan form if it:
(1) successfully completes all fields in Elements 1–20 in Parts A–E, and (2) successfully
completes all elements and criteria AND receives a passing score for Elements 21–27
in Part E (see Section 6.3.1).
 An issuer receives a scoring designation of “Meets” for its Progress Report form if it: (1)
successfully completes all fields in Elements 1–15 in Parts A–B, and (2) successfully
completes all elements and criteria AND receives a passing score for Elements 16–18
in Part C (see Section 6.3.2).
 An issuer receives a scoring designation of “Meets” for its Modification Summary
Supplement form if it: (1) successfully completes all fields in Elements 1–7 in Parts A–B,
and (2) successfully completes all elements and criteria AND receives a passing score
for Element 8 in Part C (see Section 6.3.3).
 An issuer receives a “Does Not Meet” scoring designation if it is still missing any critical
information in its Implementation Plan form, Progress Report form, or Modification
Summary Supplement form following the QHP Application Period or does not receive a
passing score for Part E of the Implementation Plan form, Part C of the Progress Report
form, or Part C of the Modification Summary Supplement form after evaluation. CMS will
require the issuer to correct and resubmit its QIS form(s) following the release of the 2025
Plan Year QIS evaluation results as directed by CMS. Additionally, the issuer may be
required to develop a Work Plan to address identified deficiencies. 34
 An issuer receives a “Does Not Meet” scoring designation if it makes the same “Interim
Meets” type of error two years in a row in its Progress Report form.
An issuer can receive a scoring designation of “Interim Meets” for its Progress Report form if
one or more deficiencies prevent the issuer from receiving a passing score for Part C, but
CMS deems that the intent of the element or criterion is still understood. An example would be
a minor data entry error(s) like the rate provided does not equal the numerator divided by the
denominator. The “Interim Meets” designation requires an issuer to confirm and correct any
deficiencies in its Progress Report form in the relevant QIS upon submission(s) for the 2025
Plan Year.
Note: An issuer may not receive an “Interim Meets” designation on the same type of
error two years in a row. If an issuer makes the same type of error two years in a
row, the issuer will receive a “Does Not Meet” designation and must correct the
error within the form they submitted for the applicable plan year.


See the 2016 Payment Notice, 80 FR 10750 at 10876.
The Work Plan may be required as part of CCIIO’s QHP compliance reviews.
pg. 26

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

6.3.5

QIS Evaluation Results Communication

After CMS conducts an evaluation of complete QIS submissions to determine whether the QIS
meets the QIS requirements, communications will be made to issuers to inform them of their
evaluation results. CMS will begin evaluation after the close of the PY2025 QHP Application
Period (in calendar year 2024) and will communicate QIS evaluation results (including identified
deficiencies, potential concerns, and recommended actions) to issuers in the fall of 2024.
Exhibit 15 describes the different CMS QIS evaluation results communications.
As part of the FFE’s annual QHP Application and Certification Process, an issuer must attest to
complying with each Exchange certification standard. 35 CMS relies on that statement to affirm
issuers’ commitment to submit complete and accurate data. CMS may conduct compliance
reviews under 45 CFR § 156.715 to examine issuer compliance with the federal QIS data
submission and reporting requirements.
Exhibit 15: CMS QIS Evaluation Results Communication
Score
Meets

Conditions
CMS does not notify issuers if their QIS submissions receive an overall outcome of “Meets.”

Does Not Meet

If an issuer receives a “Does Not Meet” designation, the issuer must confirm receipt of the
feedback and correct all potential concerns following the release of the 2025 Plan Year QIS
evaluation results as directed by CMS. Additionally, these issuers may be required to develop
a Work Plan to address identified deficiencies.
If an issuer submission receives an “Interim Meets” designation for its Progress Report
submission, the issuer must confirm receipt of the feedback and correct any instances of data
entry errors in the relevant QIS submission for the 2025 Plan Year.

Interim Meets

Note: An issuer may not receive an “Interim Meets” designation on the same type of error
two years in a row. If an issuer makes the same type of error two years in a row, the issuer
receives a “Does Not Meet” designation and must correct the error for the 2025 Plan Year.

The Federally-facilitated Exchange Issuer Attestations: Statement of Detailed Attestation Responses includes the
following statement: “Applicant attests that it will comply with the specific quality disclosure, reporting, and
implementation requirements at 45 CFR §§ 156.200(b)(5) and 156 Subpart L.”

pg. 27

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Volume II. QIS User Guide for the 2025 Plan Year

pg. 28

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

User Guide Introduction

This QIS User Guide provides instructions for issuers about compliance with QIS requirements.
It describes differences in the submission process for issuers operating in an FFE state versus
those that operate in FFEs where the state performs plan management. An issuer operating in the
latter type of Exchange works directly with the state in which it is offering QHPs through the
Exchange to submit its QIS.
Issuers that meet the QIS participation criteria operating in an FFE should review the QIS
materials prior to beginning their PY2025 QHP applications. 36 Issuers should also review the
2025 Final Letter to Issuers for additional guidance specific to the 2025 Plan Year.

1.1

Access the QIS Materials on the MQI Webpage

The QIS materials specific to each plan year will be accessible via the MQI website prior to the
start of the QHP Application Period. The MQI website is an online resource for issuers that
houses information about ongoing Marketplace quality initiatives, such as the QRS and QHP
Enrollee Survey. 37
Follow these step-by-step instructions to access and review the QIS materials online via the MQI
website:
Step 1: Select this link to open the QIS Data Collection page on the MQI website.
If the website does not automatically open, copy and paste the link below into an Internet
browser (e.g., Internet Explorer®, Google Chrome®, Mozilla Firefox®):
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-AssessmentInstruments/QualityInitiativesGenInfo/ACA-MQI/Quality-Improvement-Strategy/QIS-DataCollection.html.
Step 2: Select each QIS-related document and select the file name to view it.
Step 3: Under the “File” tab, select “Print” or “Save,” as desired.

1.2

Determine Which QIS Form(s) to Complete

There are three separate QIS forms: the Implementation Plan form, Progress Report form, and
Modification Summary Supplement form. Issuers participating in an FFE and FFEs where the
state performs plan management that meet the QIS participation criteria, regardless of
submission type, must use the updated QIS forms. Exhibit 16 outlines the decision criteria
issuers can use to determine which QIS form(s) to submit.

The PY2025 QHP Application Period occurs in calendar year 2024. See the 2025 Plan Year QHP Data
Submission Key Dates Timeline available on the CMS website. The 2025 Plan Year occurs in calendar year 2025.
37
While QRS and QIS materials are housed in proximity to one another, it is important to note that these are two
separate initiatives with distinct issuer reporting requirements. QRS develops public-facing QHP ratings based on
relative quality and price, while QIS requires issuers to implement quality improvement strategies that include
market-based incentives to cover all of their eligible QHPs as a condition of the QHP certification in an Exchange.
36

pg. 29

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Exhibit 16: QIS Form(s) Selection Decision Tree
Is this your first year submitting a QIS? If Yes, Submit an Implementation Plan form only.
If not, Are you changing your QIS? If not, Submit a Progress Report form only.
Y
this Are
youryou
firstmaking
year changes that warrant a modification to your existing QIS?, If not, Are you discontinuing your QIS and
IfIsyes,
Submit an Implementation Plan form only.
submitting a QIS?
implementing
a new one? If yes, Submit an Implementation Plan form for the new QIS and a Progress Report form to close
out the previous QIS. If not, Your scenario may have some special circumstances. Please contact the MSD for targeted
guidance.
N
If you are making changes that warrant a modification to your existing QIS, Have you previously submitted two Modification
N
Summary Supplement forms to change
this QIS? If yes, Submit an Implementation Plan form for the new QIS and a
Are you changing
a Progress
Report
form
only.
Progress Report form to close out theSubmit
previous
QIS. If not,
Submit
a Progress
Report form and a Modification Summary
your QIS?
Supplement form.
Y
Are you making changes
that warrant a modification to
your existing QIS?

Are you discontinuing
your QIS and
implementing a new
one?

Y Submit an Implementation Plan form for the new QIS and
a Progress Report form to close out the previous QIS.
Your scenario may have some special circumstances.
N Please contact the MSD for targeted guidance.

Y
Have you previously submitted
two Modification Summary
Supplement forms to change
this QIS?

1.3

Submit an Implementation Plan form for the new QIS and
a Progress Report form to close out the previous QIS.
Submit a Progress Report form and a Modification
Summary Supplement form.

Prepare to Complete the QIS Forms

After reviewing the Technical Guidance and User Guide, issuers submitting a new QIS must
complete the Implementation Plan form, and issuers continuing a QIS must complete the
Progress Report form (and Modification Summary Supplement form, as applicable) by following
these instructions:
Step 1: Select the PDF file(s) titled “QIS Implementation Plan form,” “QIS Progress
Report form,” and/or “QIS Modification Summary Supplement form” (as
applicable) and confirm that “2025 Plan Year” appears in the header on the first
page.
Step 2: Download the file(s) by selecting “Save As” on the “File” tab.
Step 3: Save a local copy with JavaScript® enabled to an easily accessible folder.
Step 4: Begin populating the QIS Implementation Plan form, QIS Progress Report form
and/or QIS Modification Summary Supplement form (as applicable) by following
the instructions provided in Volume II, Sections 2, 3, 4, and 5 below.
This Technical Guidance and User Guide provides information and instructions for all three
forms; however, issuers must determine which form options and instructions apply to them by
reading the detailed QIS participation criteria and/or reviewing the QIS Issuer List on the MQI
website.
Issuers are responsible for maintaining records that provide the detail required by the Exchanges
and that may be necessary to demonstrate compliance with applicable Exchange requirements as

pg. 30

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

part of an audit, compliance review, or other monitoring effort. 38 Issuers may not upload
additional materials beyond the form itself via SERFF or HIOS, and CMS will not accept any
additional materials as part of the QIS submission.
TIP: The QIS forms are fillable PDF documents that are available only electronically;
issuers may not request hard copies by mail.
TIP: To view and save the forms, download and install Adobe Acrobat Reader®, a free
electronic file reader that is available online. To complete the forms, follow the prompts to
enable JavaScript.
TIP: For assistance accessing the QIS forms online, please contact the Marketplace Service
Desk (MSD) at [email protected] or 1-855-CMS-1515.
TIP: Print a copy of this QIS User Guide so it can be viewed side-by-side with the forms
and refer to it as often as necessary. Save the forms regularly as responses are entered.

Complete Introductory Sections of the Applicable QIS Forms

All issuers must complete Parts A−C of the Implementation Plan form and/or Parts A and B of
the Progress Report form and Modification Summary Supplement form (as applicable) for the
respective QIS submission. An issuer must submit the appropriate complete form(s) to each
Exchange in which the QHP associated with the QIS is offered. Parts A and B of each form
consist of the following two sections:
•

Part A: QIS Submission Type
o Type of QIS Submission (Implementation Plan form): New after Discontinuing 39 or
New with No Previous Submission
o Type of QIS Submission (Progress Report form): Progress Report or Progress Report
Closeout form
o Type of QIS Submission (Modification Summary Supplement form): Continuing QIS
with Modifications
o Targets All QHPs and Product Types Offered Through an Exchange (found in
Implementation Plan form only)

•

Part B: Background Information
o Issuer Information
o Current Payment Model(s) Descriptions (found in Implementation Plan and Progress
Report)

In the Implementation Plan form, issuers must also complete Part C: Data Sources Used for
Goal Identification and Monitoring Progress.

See 45 CFR § 156.705.
Beginning with the PY2025 Plan Year QHP Application Period, issuers who want to make changes to their QIS
but have already submitted two Modification Summary Supplement forms to change the same QIS must submit a
Progress Report Closeout form to discontinue that QIS and submit a new Implementation Plan form to establish a
new QIS.
38
39

pg. 31

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

TIP: Issuers must complete the Submission Date field at the top of each form to indicate the
date they’re submitting the form to CMS.
TIP: Fill out all of the above parts of the form to submit a complete QIS. If any required
element and/or criterion is left blank, the issuer will receive review results indicating the
submission is missing information. The notice will include specific information on which
form, element(s) and/or criteria are missing information.
TIP: CMS will blind and redact submissions to remove any identifying information prior to
evaluation for scoring. To facilitate timely review, issuers should not include any identifying
information (e.g., issuer name, state, any proprietary products) in their responses to the
elements and criteria in the QIS forms, except in Part B: Issuer Information.
The subsections below provide instructions on how to complete each section. These subsections
also provide information about the elements and criteria, the level of detail expected in issuers’
responses, and applicable character limits for each form.
Issuers must use the space provided in the QIS forms to provide their responses; inclusion of
additional attachments and/or supporting documentation will not be accepted. The forms allow
issuers to copy and paste language from other documents (e.g., Microsoft Word® documents)
into the response fields, as long as the pasted text does not exceed the field’s character limits.
TIP: The character limits specified include spaces and punctuation.

2.1

Part A. QIS Submission Type

Part A of each of the QIS forms ask issuers to identify what type of QIS submission they are
making. During the PY2025 QHP Application Period, issuers will complete the Implementation
Plan form to submit a new QIS with no previous QIS submission, to implement a new QIS after
discontinuing an existing QIS, or to implement a new QIS while continuing to report on progress
for an existing QIS. 40 Issuers will complete the Progress Report form to report on progress for an
existing strategy they’re continuing or to close out an existing strategy. Issuers will also need to
submit the Modification Summary Supplement form if they wish to modify components of an
existing QIS related to topic areas, product types, goals, activities, measures, or performance
targets. Part A is designed to guide issuers to complete the correct parts of the QIS form,
depending on the type of QIS submission they are making. CMS requires completion of all Part
A elements, but will not score them. There are associated criteria in Part A of the Implementation
Plan form, but there are no associated criteria in Part A of the Progress Report form or
Modification Summary Supplement form.
Issuers continuing a QIS will NOT need to complete and submit the Implementation
Plan form, only the Progress Report form (and Modification Summary Supplement
form, as applicable).

Appendix D defines these QIS submission types and indicates which sections of the QIS form issuers must
complete depending on the applicable scenario.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Follow the steps below to select the appropriate QIS submission type in Part A:
Step 1: Indicate what type of QIS submission is being completed by selecting the
appropriate option in Element 1.
Select the available option on the respective form that describes what type of QIS submission the
issuer is making (i.e., “Implementing a New QIS with No Previous QIS Submission” or
“Implementing a New QIS After Discontinuing a QIS Submitted During a Prior QHP
Application Period” in the Implementation Plan form, the “Progress Report” or “Progress Report
Closeout Form” in the Progress Report form, or “Continuing a QIS with Modifications” in the
Modification Summary Supplement form).
An issuer that does not submit a QIS during the PY2024 QHP Application Period and newly
meets the QIS participation criteria for the 2025 Plan Year must select “New QIS with No
Previous QIS Submission.” An issuer that submitted a QIS during the PY2024 QHP Application
Period and would like to implement a new QIS while continuing to report on progress for an
existing QIS must also select “New QIS with No Previous QIS Submission.” 41 All other issuers
that submitted a QIS during the PY2024 QHP Application Period must select from the other
submission type options and complete the required sections of the form(s).
If an issuer wants to discontinue its existing QIS and submit a new QIS, it must complete two
forms: a Progress Report form to close out and discontinue the existing QIS and an
Implementation Plan form for its new QIS. An issuer that is continuing its QIS but wishes to
modify components related to topic areas, product types, goals, activities, measures, or
performance targets must complete two forms: a Progress Report form to report progress on its
QIS and the Modification Summary Supplement form to capture the modifications to its existing
QIS. Beginning with the PY2025 QHP Application Period, issuers who want to make changes to
their QIS but have already submitted two Modification Summary Supplement forms to change
the same QIS must submit a Progress Closeout form to discontinue that QIS and submit a new
Implementation Plan form to establish a new QIS. See Appendix B for additional information on
how to complete Part A of the forms.
The required sections of the QIS form are determined by the type of QIS submission as specified
in Part A.
Step 2: Identify whether the QIS applies to all eligible QHPs the issuer offers or is seeking
to offer through the Exchange by checking the appropriate box in Element 2
(Implementation Plan only).
To complete Criterion 2a in the Implementation Plan form, check the box for “All QHPs” if the
QIS applies to all eligible QHPs included in the current year’s QHP Application. Check the box
for “Subset of QHPs” if the QIS covers only some of the eligible QHPs offered by the issuer
through the Exchange.

A “new QIS” is defined as either a QIS that has not been previously submitted to an Exchange OR a QIS that
differs from an issuer’s prior QIS due to changes in market-based incentive or certain other components that warrant
a modification to an existing QIS.
41

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

TIP: Eligible QHPs are health plans within a product type that meets the minimum
enrollment threshold (i.e., the product type had more than 500 on-Exchange enrollees per
state as of July 1, 2023). QHPs within product types that do not meet the minimum
enrollment threshold (i.e., non-eligible QHPs) are not required to be covered by a QIS. 42 For
more information about QHP eligibility with respect to an issuer’s QIS, refer to Section 5.2
of the Technical Guidance.
TIP: If this QIS covers only a subset of the issuer’s eligible QHPs offered through the
Exchange, an issuer must submit an additional QIS for each eligible QHP offered by the
issuer through an Exchange.
TIP: 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 to cover each 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 ensure all eligible QHPs are covered by an existing or new QIS.
To complete Criterion 2b in the Implementation Plan form, check the appropriate box(es) to
indicate the product type(s) (e.g., HMO, POS) to which the QIS applies for the 2025 Plan Year.
TIP: If an issuer is adding or removing product types to an existing QIS, the issuer should
reflect that in the Modification Summary Supplement form.

2.2

Part B. Issuer Information

Part B of all three QIS forms collects identifying information about the issuer (e.g., issuer legal
name, company legal name, HIOS Issuer ID, issuer state, QIS contact information, date issuer
began offering coverage through the Exchanges, information about the issuer’s current payment
models). CMS requires responses to all Part B elements, but will not score them. There are no
associated criteria requested in Part B.
Follow these steps to complete Part B. Issuer Information in the Background Information in all
three forms:
Step 1: Enter the issuer’s legal name into the space provided for Element 3 (PR 2, MS
2 43).
Provide the legal name of the issuer that offers the QHP(s) to which the QIS applies.
TIP: The information provided in the issuer’s responses to Elements 3–6 (PR 2–5, MS 2–4)
(i.e., the legal names of the issuer and the issuer’s parent company, the issuer’s HIOS Issuer
ID, and the state in which the issuer is located) should match the information provided on
the application templates completed as part of the issuer’s QHP Application for the 2024
Plan Year. Once a Modification Summary Supplement form has been submitted, it is
considered part of the Implementation Plan on file. Therefore, in the following plan year,
See supra note 14.
Element numbers vary between the Implementation Plan, Progress Report, and Modification Summary
Supplement. For clarity, “(PR #, MS #)” has been added after each Implementation Plan element reference to
indicate the corresponding element in the Progress Report form or Modification Summary Supplement.
42
43

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

issuers reporting on progress should report on the modified information (if applicable)
contained in the Modification Summary Supplement form.
TIP: If the issuer previously completed Elements 3–16 (PR 2–15, MS 2–7) in its
Implementation Plan form and is now submitting a Progress Report form for its existing
QIS, the issuer should review its prior years’ responses to these elements and make any
necessary updates. It is important that the issuer confirms the responses to these elements
are current. Changes to these background elements do not warrant a modification or require
completion of a Modification Summary Supplement form.
Step 2: Enter the legal name of the issuer’s parent company into the space provided for
Element 4 (PR 3).
Provide the legal name of the parent company with which the issuer is affiliated. In some cases,
the legal name of the issuer and the legal name of the parent company are the same.
Step 3: Enter the issuer’s HIOS Issuer ID in the space provided for Element 5 (PR 4,
MS 3).
Enter the HIOS Issuer ID, which is a five-digit numeric identifier that is assigned to each issuer
during HIOS registration. 44
TIP: For help obtaining or remembering the issuer’s HIOS Issuer ID, please contact the
Marketplace Service Desk at [email protected] or 1-855-CMS-1515.
Step 4: In Element 6 (PR 5, MS 4), name the state in which the issuer is domiciled.
Enter the name of the jurisdiction (i.e., the state, territory, or the District of Columbia) in which
the issuer is domiciled. Abbreviate the jurisdiction name using standard postal abbreviations. For
example, Virginia should be represented as “VA” and the District of Columbia should be
represented as “DC.”
Step 5: Identify and provide contact information for the issuer’s QIS primary point of
contact (POC) in Elements 7–10 (PR 6-9, MS 5-7).
Provide the first and last name, title, phone number, and email address of the issuer’s staff
member who is responsible for filling out the QIS form(s) and/or is familiar with the issuer’s
QIS.
Step 6: Identify and provide contact information for the issuer’s QIS secondary POC in
Elements 11–14 (PR 10-13).
Provide the first and last name, title, phone number, and email address of a second staff member
who is responsible for filling out the QIS form(s) and/or is familiar with the issuer’s QIS.

The HIOS Issuer ID and the HIOS Plan ID (also known as an SCID) are two different identifiers. The former is a
five-digit numeric identifier assigned to issuers upon HIOS registration; the latter is a unique 14-digit number
assigned to health plans in HIOS.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Step 7: Enter the date the issuer began offering coverage through the Exchange in the
space provided for Element 15 (PR 14).
Enter a date that specifies when the issuer began offering coverage through the Exchange by
following this format: MM/DD/YYYY. For example, an issuer might indicate that it began
offering coverage through the Exchange on 01/01/2014.
TIP: Issuers operating in multiple Exchanges must submit at least one QIS for each state in
which they operate.
Step 8: Select one or more of the categories of payment models listed in Element 16
(PR 15).
Check the box or boxes that represent the category(ies) of payment models used by the issuer
across its Exchange product line.
The information provided in Element 16 (PR 15) will help CMS gauge progress toward meeting
value-based payment goals. 45 Exhibit 17 provides a description of each of the four categories.
Exhibit 17: Examples of Payment Models by Category 46
Payment Category

Description

Fee for Service (FFS)–
No Link to Quality and Value

Payments are based on volume of services and not linked to quality and
efficiency.

Fee for Service (FFS)–
Linked to Quality and Value

At least a portion of payments vary based on the quality and efficiency of
health care delivery.

Alternative Payment Models
(APMs) Built on FFS
Architecture

Some payment is linked to the effective management of a segment of the
population or an episode of care. Payments are still triggered by delivery of
services, but there are opportunities for shared savings or two-sided risk.

Population-based Payment

Payment is not directly triggered by service delivery, so payment is not
linked to volume. Clinicians and organizations are paid and responsible for
the care of a beneficiary for a long period (e.g., more than one year).

Enter the percentage of payments (i.e., the percentage of payment dollars) to providers in the
space provided for each of the payment model types selected. These can be estimated percentage
breakdowns. Please confirm that the total percentage of payments across all four payment model
type categories equals approximately 100 percent.
TIP: Round percentages to the nearest whole number (e.g., 2). Do not enter decimal places
(e.g., 1.73), fractions (e.g., 1¾) or percent signs (e.g., %).
TIP: To calculate the percentage of payments, use the calculation methodologies defined in
the APM Framework: http://hcp-lan.org/workproducts/apm-refresh-whitepaper-final.pdf.

https://hcp-lan.org/apm-refresh-white-paper/
Categories of payment models are defined in the APM Framework: http://hcp-lan.org/workproducts/apm-refreshwhitepaper-final.pdf
45
46

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Complete the QIS Implementation Plan Form (Part C. Data Sources,
Part D. QIS Summary, and Part E. QIS Requirements)

For the 2025 Plan Year, eligible issuers starting a new QIS must complete and submit the
Implementation Plan form to CMS. This submission will establish a baseline Implementation
Plan form, which will be kept on file with CMS. Issuers continuing a QIS no longer need to
complete and submit an Implementation Plan form after the first year. In addition to Parts A and
B described in the previous section, an Implementation Plan form consists of the following
sections:
•
•

Data Sources Used for Goal Identification and Monitoring Progress
o Part C: Data Sources

QIS Implementation Plan Section
o Part D: QIS Summary
o Part E: QIS Requirements

TIP: Fill out all of the above parts of the form to submit a complete Implementation Plan
form. If any required elements and/or criteria are left blank, the issuer will receive review
results indicating that the submission is missing information. The review results will include
specific information on which element(s) and/or criteria need information to be revised and
resubmitted during the QHP Application Period. Note: ONLY the form in which the error
is identified needs to be resubmitted.
The subsections below provide instructions on how to complete each part of the Implementation
Plan form. Refer to Appendix C for an element-by-element summary.
TIP: Prior to submitting the Implementation Plan form to CMS, an issuer should use the
QIS Forms Pre-Submission Checklist provided in Appendix B to confirm it has provided
responses to all required 47 elements—including must-pass elements—and criteria. This
checklist also helps guide issuers through the submission process.

3.1

Part C: Data Sources

Part C of the Implementation Plan form collects information about the data sources the issuer
used to inform the development and implementation of its QIS. CMS uses the information
requested in this element to understand how an issuer identified the goals and developed the
rationale for its QIS. An issuer must provide a response to this element, but CMS will not score
the response.
Follow this step to complete Part C in the Background Information section of the Implementation
Plan form:

For example, if an issuer does not select “Other Market-based Incentives” in Element 21, the issuer does not need
to provide a description in the text box.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Step 1: Indicate the data sources that were used to identify the problem or topic area that
the QIS aims to address by checking the appropriate box(es) in Element 17.
Issuers may rely on a number of different data sources to inform their strategies. These data
sources include but are not limited to: internal issuer enrollee data; medical records; claims files;
surveys (including the QHP Enrollee Survey); plan data, such as complaint, appeals, and
customer service records; registries; U.S. Census data; the Area Health Resource File (AHRF); 48
all-payer claims data; state health department population data; and/or regional collaborative
health data.
Check one or more boxes to indicate which of the data sources listed in Element 17 the issuer
used to identify the needs of the QHP enrollee population and supporting QIS rationale. If the
issuer used one or more data sources that are not provided on the list, check “Other” and name
the appropriate data source(s) in the space provided.
Issuers checking the box for “Other” should not include company identifying information in their
data source description.
TIP: If the issuer checks the box for “Census data,” it should make sure to specify which
type of Census data (e.g., tract, ZIP Code, block) was used to identify the problem(s) and to
monitor its QIS progress.

3.2

Part D. QIS Summary

Part D of the Implementation Plan form collects information that summarizes the issuer’s QIS
(i.e., QIS title and description). Responses to both elements in Part D are required, but CMS will
not score these responses. There are no associated criteria requested in Part D.
Follow these steps to complete Part D. QIS Summary in the Implementation Plan form:
Step 1: Provide a title for the QIS in the space provided for Element 18.
The QIS title provided in Element 18 should be brief, but descriptive.
Step 2: Provide a brief summary description of the QIS in the spaces provided for
Element 19.
The QIS description is a snapshot of some of the elements covered in more detail in Part E of the
Implementation Plan form. The QIS description should specify the market-based incentive
type(s) (e.g., provider, enrollee) and the QIS topic area (e.g., improve health outcomes, prevent
hospital readmissions). These two pieces of information should be derived from the issuer’s
responses to Elements 21 and 22, respectively, in Part E of the Implementation Plan form.
As mentioned in the Technical Guidance, a QIS must incentivize quality by tying payments to
measures of performance when providers meet specific quality indicators or enrollees make
certain choices or exhibit behaviors associated with improved health. Failing to incentivize
quality will result in the QIS submission receiving an overall score of “Does Not Meet.”

The AHRF databases can be accessed at: http://ahrf.hrsa.gov/.
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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Indicate if this QIS is part of a mandatory state initiative. This information will provide context
for why the issuer has chosen to implement this QIS.
Indicate if this QIS is one that the issuer currently has in place for an Exchange product line
and/or for other product lines (e.g., Medicaid, commercial). Issuers may use existing strategies
that are employed in non-Exchange product lines if the existing strategy is relevant to their
Exchange population and meets the QIS requirements. 49 Issuers may also use information
submitted to a recognized accrediting entity for QIS purposes if the information otherwise
satisfies the QIS requirements.
If the issuer checks “Yes” for the mandatory state initiative question or the currently existing
strategy question, it should describe the initiative(s) in the space provided.
Step 3: Describe the QIS.
The QIS description should provide a brief summary of the strategy and must address the
market-based incentive type (identified in Element 21) and topic area selected (Element 22).
TIP: Since the QIS description (Element 19) closely relates to the issuer’s responses to
elements and criteria in Part E (i.e., Elements 21 and 22), double-check the consistency and
the completeness of these responses to each element and criterion throughout the
Implementation Plan prior to submission.

3.3

Part E. QIS Requirements

Part E of the Implementation Plan form collects detailed information about the QIS for
evaluation. Responses to all elements are required and scored by CMS (with the exception of
Element 20, which is required but will not be scored). In addition, there are associated criteria
requested in Part E that are also required and scored by CMS.
TIP: Responses are required for all Part E elements and criteria. Five of the seven elements
in Part E are considered must-pass elements. Issuers that do not provide sufficient and/or
appropriate information for those elements will be required to submit additional information
for a second review.
The section below describes the elements and criteria issuers must populate in Part E in the
Implementation Plan form. Contextual information (e.g., statement of goals, listing of activities)
is required, but will not be scored. If any element is left blank, the issuer will receive notification
that its submission is missing information. The notification will specify which element(s) and/or
criteria need to be revised and resubmitted.
Follow these steps to complete Part E. QIS Requirements in the Implementation Plan form:
Step 1: Describe the overall goal(s) of the QIS (no more than two goals).
Element 20 should cover the overall goal(s), drawing a clear link between the goal(s) and the
topic area(s) selected in Element 22. Issuers must address at least one, but no more than two,
goals in support of their QIS.

For a detailed discussion of the QIS requirements, please refer to Volume I, Section 5: QIS Requirements.
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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

TIP: Issuers should not include specific performance targets or tie goals to a specific
calendar year or plan year because the Implementation Plan form will remain on file and
references to specific years or performance targets will likely become outdated over time.
Step 2: Select at least one of the market-based incentive types listed in must-pass
Element 21.
To complete Element 21, select the box(es) for the market-based incentive sub-type(s) (e.g.,
increased reimbursement, bonus payment, premium credit, co-insurance reduction 50) the QIS
includes. An issuer may choose to implement a provider market-based incentive, an enrollee
market-based incentive, or both.
TIP: Incentives do not necessarily need to be monetary in nature, but must create some
added value that would otherwise not be received (e.g., additional service, premium credit).
If “In-kind incentives,” “Other provider market-based incentives,” and/or “Other enrollee
market-based incentives” is selected as a market-based incentive sub-type, include a brief
description in the corresponding space(s) provided.
TIP: Refer to Appendix E for additional information to complete Element 21.
Step 3: Select at least one of the topic areas listed in must-pass Element 22.
To complete Element 22, check the box(es) for at least one topic area the QIS addresses, as
defined in the PPACA. 51 Issuers may select more than one topic to address with a single QIS.
TIP: QHP issuers are required to select “Reduce health and health care disparities” as a
topic area within at least one of their quality improvement strategies on file. Issuers may
achieve this by either submitting one Implementation Plan that selects at least one topic area
in addition to “Reduce health and health care disparities;” by submitting two
Implementation Plans, one that selects the “Reduce health and health care disparities” topic
area and another that focuses on another topic area; or by submitting multiple
Implementation Plans with at least one that selects the “Reduce health and health care
disparities” topic area.
TIP: If an issuer selects “Reduce health and health care disparities” as a topic area, it must
state the population(s) addressed by the quality improvement strategy.
TIP: If an issuer wants to change its topic area selections for an existing QIS, it must submit
a Modification Summary Supplement form.

Any enrollee financial incentives used as part of an issuer’s QIS must comply with other applicable federal and
state requirements, including, but not limited to, those applicable to premiums and rating, plan design, and actuarial
value. For example, wellness program incentives must comply with the federal wellness program regulations at 26
CFR § 54.9802-1(f), 29 CFR § 2590.702(f), and 45 CFR § 146.121(f).
51
Section 1311(g)(1) of the PPACA.
50

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Step 4: Enter a rationale for the QIS in the space provided for must-pass Element 23. The
rationale should include both a description of the issuer’s current QHP enrollee
population and how the QIS will address the needs of the current population. 52
Step 5: List the activities implemented to achieve the identified goals. Describe how the
activities advance the QIS in the space provided in must-pass Element 24. Be sure
to address all of the specified criteria (i.e., a–c)
The activities listed should relate to the goal(s) of the QIS (consistent with the goals identified in
Element 20) and should advance the QIS as it relates to: (1) the market-based incentive chosen in
Element 21 and (2) the topic area(s) chosen in Element 22.
For example, assume an issuer selects “Preventing hospital readmissions” and “Reduce health
and health care disparities” as its QIS topic areas, “Bonus payments” to providers as its marketbased incentive, and “reducing readmission rates for the age 64-and-under patient population
with an index admission of heart failure from the baseline assessment” as its goal. The issuer’s
QIS activities could include: (1) developing a bonus payment structure based on hospitals
meeting measure targets related to providing discharge planning and post-discharge care
coordination; (2) establishing an in-hospital visiting nurse program to support development of
post-discharge patient care plans and; (3) developing communications materials for patients and
providers in Spanish, Mandarin, and Creole that discuss the importance of follow-up care visits
and compliance with the post-discharge care plan and providing information on community
supports and services.
To complete Criterion 24a, list the activities that will be implemented to achieve the identified
goals.
To complete Criterion 24b, describe how the QIS activities relate to the selected market-based
incentive.
To complete Criterion 24c, describe how the activities relate to the selected topic area(s).
Step 6: Name goal(s), measure(s), and performance targets to monitor QIS progress in the
spaces provided in must-pass Element 25. Be sure to address all of the specified
criteria.
For each goal, identify at least one (but no more than two) primary measures that are used to
track progress against the goal by providing the measure name(s) in Criteria 25a, 25f, 25k, and
25p.
Issuers are required to have quantitative measures, but have flexibility in selecting their
measures. Outcome measures, as well as measures of patient experience and value, are preferred
over process measures. Issuers will submit an annual Progress Report form that includes a
description of progress of QIS implementation activities and an analysis of progress using
measures and targets in Element 16 of the Progress Report form. Issuers will also have the
opportunity to provide a narrative description of progress made against those measures in
Element 17 of the Progress Report form.

In this context, “current” refers to the QHP enrollee population over the past two years.
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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

TIP: Issuers may use measures developed by their own organizations (i.e., homegrown
measures) or by other developers.
TIP: Issuers are not required to use QHP Enrollee Survey results and/or QRS survey results
as QIS baseline assessment data. Issuers may choose to use survey results or may choose to
use other data sources that identify QHP enrollee population needs and support their QIS
rationale for QIS baseline assessment data in Element 25 of the Implementation Plan form.
For Criteria 25a, 25f, 25k, and 25p, in addition to the measure name, an issuer must provide a
narrative description of the measure, including a clear description of the measure numerator and
denominator if a rate was provided. If the issuer provided a data point for the measure, a clear
description of how the data point was calculated must be provided in Criterion 25a. Next, the
issuer should specify whether it is using a consensus-based entity (CBE)-endorsed measure by
checking “Yes” or “No.” 53 If it selects “Yes,” the issuer should provide the CBE ID in the space
provided and indicate whether the issuer modified the CBE-endorsed measure specifications.
TIP: Issuers are not required to use CBE-endorsed measures to complete Element 25.
However, if an issuer chooses to do so, it must include the measures’ CBE IDs in the spaces
provided.
TIP: While CMS does not currently require issuers to select measures from a set of specific
measures, use of standardized or uniform performance measures is strongly encouraged.
CMS encourages issuers to use national, state, or regional benchmarks when establishing their
QIS performance targets. Further, CMS encourages issuers to select measures and performance
targets in areas where there is room for improvement, based on these established benchmarks.
For example, issuers may reference benchmarks for the measures collected for the Quality
Rating System (QRS) via the Nationwide QRS Public Use File (PUF). 54 CMS releases the
Nationwide QRS PUF annually and anticipates releasing the PUF prior to the start of the
individual market open enrollment period. 55
For Criteria 25b, 25g, 25l, and 25q, issuers must provide a narrative description of how each
measure supports tracking performance related to the corresponding QIS goal. Issuers must also
use this space to provide additional detail on what the performance target (Criteria 25e, 25j, 25o,
and 25t) represents.
For Criteria 25c, 25h, 25m, and 25r, issuers must provide the baseline assessment results by
either calculating the rate or determining the applicable data point. If the measure is a rate, the
numerator and denominator provided should calculate to the numerical value provided. If the
measure is not a rate, enter the applicable data point as a numerical value in the space provided.
The CBE sets measure evaluation criteria through experts and multi-stakeholder groups involved in the evaluation
process. For further details regarding CBE endorsed quality measures, please visit the CBE measure database
(http://www.p4qm.org/measures).
54 54
The Nationwide QRS PUF for Plan Year 2024 is available for download on the CMS MQI website:
https://www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/qualityinitiativesgeninfo/acamqi/downloads/mqi-downloads.
55
The individual market open enrollment period starts on November 1 of the calendar year before the applicable
plan year. See 45 CFR 155.410(e)(4). The 2025 Plan Year individual market open enrollment period will begin on
November 1, 2024.
53

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

TIP: “Baseline data” is the initial collection of data that serves as a basis for comparison
with the subsequently acquired data. For QIS, issuers should use the data from their initial
QIS Implementation Plan if they have not modified their measures.
TIP: Baseline assessment results should measure an issuer’s performance before
implementation of the QIS.
TIP: Due to the timing and availability of certain measure data (e.g., Healthcare
Effectiveness Data and Information Set [HEDIS®] measure rates), issuers may not have all
the final baseline data needed to complete their QIS submissions by the final QHP
submission deadline. Issuers may submit their QIS with preliminary data in the measure
fields and an appropriate explanation in the Optional field at the end of the form. If the final,
validated measure rates differ from what was submitted in the Implementation Plan, issuers
may update their QIS by submitting Modification Summary Supplement form with updated
baseline data in the following plan year’s QHP Application Period.
TIP: Check for data entry errors. Ensure that the rate provided is equivalent to the
numerical value created when the numerator is divided by the denominator.
For Criteria 25d, 25i, 25n, and 25s, the issuer must specify the baseline performance period (e.g.,
measurement year) covered by the baseline data assessment provided in the Implementation Plan
on file for each respective QIS.
To complete Criteria 25e, 25j, 25o, and 25t, provide the performance target for each specified
measure.
TIP: The numerical value performance target should be a rate (%) or a data point target,
NOT a percentage change.
TIP: At this time, issuers 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.
TIP: Performance targets should be numerical values (e.g., target of 90 percent) and NOT
percentage changes (e.g., improvement of 10 percent).
Step 7: Provide a timeline for implementing the QIS in the space provided in scored
Element 26. Be sure to address all of the specified criteria.
The timeline should include the QIS initiation/start date in Criterion 26a. Enter the date using the
following format: MM/YYYY. The QIS initiation/start date should be the first month of the plan
year in which the issuer first began or will first begin implementing the QIS for the Exchange
product types and health plans specified in Element 2.
For example, an issuer that submitted its initial Implementation Plan form during the PY2019
QHP Application Period (calendar year 2018) and its initial Progress Report form during the
PY2020 QHP Application Period (calendar year 2019) should list its QIS initiation/start date as
01/2019 or earlier for its continued QIS submissions.
An issuer submitting a new Implementation Plan form for the first time during the PY2025 QHP
Application Period (calendar year 2024) should list its QIS initiation/start date as 01/2025 or
earlier (if applicable).
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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

TIP: For Criterion 26b, the timeline should also include the dates of defined milestones. At
least one milestone is required. Enter the dates of defined milestones using the following
format: MM/YYYY. Dates of defined milestones should occur after the QIS initiation/start
date entered in Criterion 26a.
The dates and milestones provided for those criteria must correspond to the activities described
in Element 24. Issuers will not be penalized if they need to adjust their timelines or redefine their
milestones as they move forward with implementation. However, the issuer’s QIS initiation/start
date in Criterion 26a should remain the same as the prior year’s submission when continuing a
QIS.
Step 8: Provide a risk assessment that describes known or anticipated barriers and
mitigation activities in the space provided in scored Element 27. Be sure to address
both of the specified criteria.
Describe all known or anticipated barriers to implementing QIS activities in Criterion 27a. If no
barriers were identified, describe how the issuer assessed risk in the next box.
To complete Criterion 27b, describe the mitigation activities the issuer will incorporate into the
QIS (if needed) for each barrier identified in Criterion 27a. Issuers will not be penalized for any
barriers they may encounter.
Step 9: If applicable, provide any additional information on the Implementation Plan
form that reviewers may find useful in the Optional text box. This field will not be
scored.
Step 10: Save the completed Implementation Plan form after verifying responses have been
provided to address all of the required elements and criteria.
Review the form to make sure responses have been provided for all required elements and
criteria. CMS will notify issuers that leave required elements blank and/or do not meet the
evaluation threshold for each element of these deficiencies and instruct these issuers to correct
and resubmit their Implementation Plans during the QHP Application Period.
Save the completed Implementation Plan form as a PDF file. The file name should follow this
naming convention: [5-digit HIOS Issuer ID]_[Issuer Name]_QIS_[IP]. For example, a file
named “12345_Issuer ABC_QIS_IP” adheres to the appropriate naming convention.
If an issuer submits more than one QIS form, the file name for each form should also contain a
numerical identifier: [5-digit HIOS Issuer ID] [Issuer Name]_QIS__[IP]_[#]. For example, if
an issuer submits two Implementation Plan forms, the first file should be named “12345_Issuer
ABC_QIS_IP_1” and the second file should be named “12345_Issuer ABC_QIS_IP_2.” All QIS
forms must follow these naming conventions when submitted.
TIP: Issuers should keep a copy of the completed Implementation Plan form and make it
available to any staff who may be responsible for QIS implementation and reporting. Issuers
should refer to their completed Implementation Plan form each year to facilitate any
corrective actions they may need to take based on the QIS evaluation results and to help
complete the Progress Report form and Modification Summary Supplement form, if
applicable, in future years.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Complete the QIS Progress Report Form

In each subsequent year following the submission of an Implementation Plan form, an issuer
must submit a Progress Report form to the applicable Exchange. The Progress Report form
collects information about the issuer’s progress in implementing its QIS. Note: Issuers
completing a Progress Report form NO LONGER need to resubmit the Implementation
Plan form for a continuing QIS. Issuers also use the Progress Report form to discontinue and
close out an existing QIS.
Issuers that submitted an Implementation Plan form, Progress Report form, or Modification
Summary Supplement form for the 2024 Plan Year are required to report on activities conducted
to implement the QIS by completing and submitting applicable section(s) of the 2025 Plan Year
Progress Report form. Issuers submitting a QIS for the first time during the PY2025 QHP
Application Period are not required to submit a Progress Report form until the PY2026 QHP
Application Period.
To complete the Progress Report form, issuers must perform all of the following activities:
•
•
•
•
•

4.1

Enter submission date at the top of the first page,
Attest that they have reviewed the Implementation Plan form on file in preparing the
Progress Report form to ensure all the baseline information is correct,
Complete the QIS Submission Type section (Part A),
Confirm the Issuer Information section (Part B) is accurate or include updates from the
prior year, if necessary, and
Complete the Progress Report section (Part C).

Part A: QIS Submission

There are two QIS Submission Types for the Progress Report form: “Progress Report” and
“Progress Report Closeout Form.”
If an issuer is continuing an existing QIS and is NOT making changes that warrant a
modification, they should select the “Progress Report” option and ONLY complete the Progress
Report form. If an issuer is continuing an existing QIS and is also making changes that warrant a
modification, they should select the “Progress Report” option, complete the Progress Report
form, and submit a Modification Summary Supplement form.
If an issuer is discontinuing an existing QIS in PY2025, they should select the “Progress Report
Closeout Form” option, complete the Progress Report form, and submit an Implementation Plan
form.
Issuers must restate the title of the QIS that the Progress Report form applies to in this section.

4.2

Part B: Issuer Information

Part B of the Progress Report form captures the same issuer information as Part B of the
Implementation Plan form. Responses to all elements are required, but are not scored by CMS.
See Section 6.3.2 of the Technical Guidance for more details.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Updates or changes to the issuer information captured in Part B of an Implementation Plan form
do not warrant a modification to an existing QIS. 56 These types of changes can instead be
reported by submitting the updated information in Part B of the Progress Report form for the
applicable QIS.

4.3

Part C. Progress Report Summary

Part C of the Progress Report form collects detailed information about the progress of the
issuer’s QIS for evaluation and information on the discontinuation of a QIS, if applicable.
Responses to all elements and criteria are required. Contextual information (e.g., restatement of
goals, listing of activities) will not be scored. The criteria for the progress report results will be
scored.
The discussion that follows outlines the elements and criteria issuers must populate in Part C of
the Progress Report form. If any element is left blank, the issuer will receive notification that its
submission is missing information. The notification will specify which element(s) and/or criteria
need to be revised and resubmitted.
Follow these steps to complete Part C. Progress Report Summary in the Progress Report form:
Step 1: If an issuer selected “Progress Report” or “Progress Report Closeout Form” in
Element 1, the issuer should restate the goals and baseline data provided in
Elements 20 and 25 of the Implementation Plan form, or Element 8 of the
Modification Summary Supplement form, if applicable.
TIP: If an issuer is continuing a QIS and did not submit a Modification Summary
Supplement form during the 2024 Plan Year in calendar year 2023, the baseline assessment
results reported in Element 16 of the 2025 Plan Year Progress Report form should match the
baseline assessment results reported in Element 25 of the Implementation Plan form on file.
TIP: If an issuer is continuing a QIS with modifications for the 2024 Plan Year (i.e., the
issuer submitted a Modification Summary Supplement form during the PY2024 QHP
Application Period in calendar year 2023 describing the modifications that will be
implemented to its QIS by January 1, 2024), the baseline assessment results reported in
Element 16 of the 2025 Plan Year Progress Report form should match the baseline
assessment results reported in Element 8 of the 2024 Plan Year Modification Summary
Supplement form.
TIP: If an issuer intends to modify its QIS for the 2025 Plan Year by submitting a
Modification Summary Supplement form during the PY2025 QHP Application Period in
calendar year 2024, the baseline assessment results reported in Element 16 of the Progress
Report form for the 2025 Plan Year should still reflect the baseline assessment results
reported in Element 25 of the Implementation Plan form on file. This is because the
modified measures described in the 2025 Plan Year Modification Summary Supplement

See Section 5.3.1, Section 5.3.2, Exhibit 4, and Exhibit 5 of this Technical Guidance, for information on the types
of updates to an existing QIS that do not warrant a modification or otherwise trigger the requirement to submit the
Modification Summary Supplement form.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

form will not be implemented in an issuer’s QIS until after submission of the 2025 Plan
Year Progress Report in calendar year 2024.
The issuer should analyze progress by providing follow-up results and indicating whether the
performance target in Element 25 of the Implementation Plan form or Element 8 of the
Modification Summary Supplement form, if applicable, was met in must-pass Element 16. Be
sure to address all five of the specified criteria.
In the space provided, restate the goals and baseline data provided in Elements 20 and 25 of the
Implementation Plan form, or Element 8 of the Modification Summary Supplement form, if
applicable.
Element 16 should reflect progress made on the baseline data for the QIS since the last
submission.
To complete Criteria 16a, 16h, 16o, and 16v, provide the measure name and CBE measure ID
number as indicated in Element 25 of the issuer’s Implementation Plan form, or Element 8 of the
Modification Summary Supplement form, if applicable.
To complete Criteria 16b, 16i, 16p, and 16w, restate the baseline assessment results by either
calculating the rate or determining the applicable data point. If the measure is a rate, the
numerator and denominator provided should calculate to the numerical value provided. If the
measure is not a rate, enter the applicable data point as a numerical value in the space provided.
TIP: Baseline assessment results reported in Element 16 should measure an issuer’s
performance before implementation of the QIS. Baseline data comprise the initial collection
of data that serves as a basis for comparison with the subsequently acquired data. For QIS,
issuers should use the data from their baseline Implementation Plan form if they have not
modified their measures.
TIP: Check for data entry errors. Ensure that the rate provided is equivalent to the
numerical value calculated when the numerator is divided by the denominator.
To complete Criteria 16c, 16i, 16q, and 16x, specify the baseline performance period (i.e., month
and year when data collection began and ended) covered by the baseline data assessment as
indicated in Element 25 of its Implementation Plan form or Element 8 of its Modification
Summary Supplement form, if applicable. Enter the response in MM/YYYY format.
To complete Criteria 16d, 16j, 16r, and 16y, provide the follow-up results by calculating the rate
(a numerical value) and providing the associated numerator and denominator, if applicable. If the
measure is not a rate, but another data point, enter the number in the space provided.
TIP: Baseline assessment results and follow-up results should be distinct; issuers should not
restate the baseline assessment results provided in Element 25 of the Implementation Plan
form or Element 8 of the Modification Summary Supplement form, if applicable, in Criteria
16d, 16j, 16r, and 16y.
TIP: Check for data entry errors. Ensure that the rate provided is equivalent to the
numerical value calculated when the numerator is divided by the denominator.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

TIP: Issuers will not be penalized at this time if they do not achieve performance target(s);
however, issuers may modify their performance target(s) if the original performance
target(s), as specified in Element 25 of the baseline QIS Implementation submission, is met,
or is no longer feasible or accurate. Issuers should include the modified targets in Element 8
of the Modification Summary Supplement form and should report on progress made toward
their original target in Element 16.
TIP: Due to the timing and availability of certain measure data (e.g., HEDIS measure rates),
issuers may not have all the final data needed to complete their QIS submissions by the final
QHP submission deadline. Issuers may submit their QIS with preliminary data in the
measure fields and an appropriate explanation in the Optional field at the end of the form.
To complete Criteria 16e, 16l, 16s, and 16z, specify the Progress Report form performance
period (i.e., month and year when data collection began and ended) covered by the progress
update data assessment. Enter the response in MM/YYYY format.
To complete Criteria 16f, 16m, 16t, and 16aa, restate the performance target for the measure
from the Implementation Plan or Modification Summary Supplement form on file. This entry
should be a rate (%) or a data point target, NOT a percentage change.
To complete Criteria 16g, 16n, 16u, and 16bb, indicate whether the performance target specified
in Element 25 of the Implementation Plan form or Element 8 of the Modification Summary
Supplement form was achieved by selecting “Yes” or “No.”
Step 2: In Element 17, provide a summary of progress toward achieving the performance
target(s) documented in Element 25 of the issuer’s Implementation Plan form or
Element 8 of the Modification Summary Supplement form, if applicable. Include a
description of the activity(ies) leading to the outcome in must-pass Element 17.
In Element 17, indicate why progress was or was not made toward achieving the performance
target(s) documented in Element 25 of the Implementation Plan form or in Element 8 of the
Modification Summary Supplement form, if applicable. Include a description of activities that
led to the outcome.
TIP: Regardless of whether issuers made progress toward the performance target(s) in
Criterion 17a, issuers are required to describe any barriers encountered in Element 18.
Issuers should complete Criterion 17b ONLY if they selected “Progress Report Closeout Form”
as their submission type in Element 1. These issuers should provide the rationale for
discontinuing their QIS.
Issuers should complete Criterion 17c if they received an “Interim Meets” determination within
their previous QIS evaluation results and were instructed to address a deficiency or error in
their submission for the upcoming plan year. These issuers should provide information about
changes made to their QIS to address these concerns and specify which elements/criteria they
apply to.
If the scenarios described in Criteria 17b and/or 17c do not apply, issuers should leave these
fields blank; however, all issuers must complete Criterion 17a.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Step 3: In Element 18, indicate whether the issuer faced any barriers implementing its
QIS, the mitigation activities implemented to address these barriers, and/or any
problems meeting the timelines specified in Criterion 26b of the prior year’s QIS
Implementation Plan form. Be sure to address both of the specified criteria.
To complete Criterion 18a, indicate whether any barriers were encountered in implementing the
QIS. If “Yes” is selected, describe the barriers encountered while implementing the QIS and the
mitigation activities implemented to address each barrier.
TIP: If the description of activities in Criterion 17a includes barriers to implementing the
QIS, issuers are still required to complete Criterion 18a and elaborate on those barriers and
any other barriers to implementing the QIS, if applicable, by describing the barriers and
mitigation activities implemented to address the barriers in Criterion 18a.
To complete Criterion 18b, indicate whether there were any problems meeting the timelines
specified in Criterion 26b of the Implementation Plan form. If “Yes” is selected, describe the
problems in meeting timelines and the mitigation activities implemented to address each of the
problems meeting timelines.
TIP: If the description of activities in Criterion 17a includes problems meeting timelines,
issuers are still required to complete Criterion 18b and elaborate on those problems and any
other problems in meeting timelines, if applicable, by describing the problems and
mitigation activities implemented to address the problems in meeting timelines in Criterion
18b.
Step 4: If applicable, provide any additional information on the Progress Report form
that reviewers may find useful in the Optional text box. This field will not be
scored.
Step 5: Save the completed Progress Report form after verifying responses have been
provided to address all of the required elements and criteria.
Review the form to make sure responses have been provided for all required elements and
criteria. CMS will notify issuers that leave required elements blank and/or do not meet the
evaluation threshold for each element of these deficiencies and will instruct these issuers to
correct and resubmit their Progress Report forms during the QHP Application Period.
Save the completed Progress Report form as a PDF file. The file name should follow this naming
convention: [5-digit HIOS Issuer ID]_[Issuer Name]_QIS_[PR]. For example, a file named
“12345_Issuer ABC_QIS_PR” adheres to the appropriate naming convention.
If an issuer submits more than one QIS form, the file name for each form should also contain a
numerical identifier: [5-digit HIOS Issuer ID]_[Issuer Name]_QIS__[PR]_[#]. For example, if
an issuer submits two Progress Report forms, the first file should be named “12345_Issuer
ABC_QIS_PR_1” and the second file should be named “12345_Issuer ABC_QIS_PR_2.” All
QIS forms must follow these naming conventions when submitted.

Complete the QIS Modification Summary Supplement Form

If an issuer chooses to make changes that warrant a modification to an existing QIS, the issuer
should complete the Modification Summary Supplement form in addition to the Progress Report
pg. 49

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

form. Changes to the following components warrant a modification to an existing QIS and
trigger submission of the Modification Summary Supplement form: topic areas, goals, activities,
measures, performance targets, and/or product types. 57 The Modification Summary Supplement
form is NOT a standalone form and, therefore, must always accompany a Progress Report form.
Once a Modification Summary Supplement form has been submitted, it is considered part of the
Implementation Plan on file. Therefore, in the following plan year, issuers reporting on the
progress of an existing QIS should report on the QIS using the updated information contained in
the Modification Summary Supplement form. Beginning with the 2025 Plan Year QHP
Application Period, if an issuer previously submitted two Modification Summary Supplement
forms to change the same QIS, that issuer must submit a Progress Report Closeout form to
discontinue that QIS and submit a new Implementation Plan form to establish a new QIS that
incorporates the desired changes.
To complete the Modification Summary Supplement form, issuers must perform all of the
following activities:
Enter submission date at the top of the first page,
Complete the QIS Submission Type section (Part A),
Confirm the Issuer Information section (Part B) is accurate or include updates from the
prior year, if necessary, and
Complete the QIS Modification Summary section (Part C).

•
•
•
•

5.1

Part A: QIS Submission

The only option for QIS Submission Type for the Modification Summary Supplement form is
“Continuing QIS with Modifications.”
This option and form should be selected by issuers that want to make changes that warrant a
modification to an existing QIS. 58
If an issuer is submitting a new QIS, it should instead complete the Implementation Plan form. If
an issuer is continuing an existing QIS and is NOT making changes that warrant a modification,
it should instead ONLY complete the Progress Report form.
Issuers must restate the title of the QIS the Modification Summary Supplement applies to in this
section.

5.2

Part B: Issuer Information

Part B is abbreviated in the Modification Summary Supplement form as it is not a standalone
form and this information is captured in more detail in the Progress Report form.
Issuer information captured in Part B of the Modification Summary Supplement form should
match the information entered in Part B of the Progress Report form.

57
58

Ibid.
Ibid.
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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

5.3

Part C: QIS Modification Summary

The Modification Summary Supplement form, Part C: QIS Modification Summary captures the
details of which components the issuer is modifying for the upcoming plan year. This form is
required if issuers want to change any of the following components of an existing QIS: topic
areas, goals, activities, measures, performance targets, and/or product types. Responses to the
applicable elements and criteria are required and are scored.
The discussion that follows outlines the elements and criteria issuers must populate in Part C of
the Modification Summary Supplement form. If any element or criterion is left blank but should
have been completed (as indicated by the selection the issuer made in Criterion 8a of the
Modification Summary Supplement form), the issuer will receive notification that its submission
is missing information. The notification will specify which element(s) and/or criteria need to be
revised and resubmitted.
Follow these steps to complete Part C. QIS Modification Summary in the Modification Summary
Supplement form:
Step 1: In Criterion 8a, select which components the issuer intends to modify.
TIP: Issuers must provide a high-level description of the modifications being made across
all selected components in the text box provided.
Step 2: Complete 8b through 8f, as applicable.
TIP: Issuers should ONLY complete the criteria for components that have been selected in
Criterion 8a.
If an issuer is modifying product types, the issuer should select whether it is adding or removing
the relevant product type(s) in Criterion 8b.
If an issuer is modifying topic areas, the issuer should select whether it is adding and/or
removing the topic area(s) in Criterion 8c and should describe how that topic area(s) will be
addressed within its existing QIS. If an issuer is modifying its topic area(s), the issuer must also
use the Modification Summary Supplement form to modify the goal(s) listed in Element 20 of
the Implementation Plan form on file by completing Criterion 8d and the activities listed in
Element 24 of the Implementation Plan form on file by completing Criterion 8e. The issuer may
also need to update the measures and performance targets listed in Element 25 of the
Implementation Plan form on file by completing Criterion 8f.
TIP: If an issuer selects “Reduce health and health care disparities” as an added topic area,
it must state the population(s) addressed by the QIS.
If an issuer is modifying a goal, the issuer should select which goal it is modifying in Criterion
8d (Goal 1 or Goal 2). The issuer should then describe the new goal in the text box and provide
the rationale for the modification in the following text box.
TIP: Issuers should not include specific performance targets or goals tied to a specific
calendar year or plan year because the Modification Summary Supplement form will remain
on file, and references to specific years or performance targets will become outdated over
time.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

If an issuer is modifying activities, it should describe the modified activities in the text box in
Criterion 8e, as well as the rationale for the modification in the following text box.
If an issuer is modifying measures or performance targets, the issuer should first describe the
modification in the text box in Criterion 8f. This description should include an explanation of
whether the issuer is adding or removing a measure, changing measure specifications, or
changing a measure target.
TIP: Issuers must provide all measure criteria (i.e., measure name, CBE ID number,
baseline assessment results, baseline performance period, and performance target) for each
measure selected for modification, even for criteria that are remaining the same.
TIP: To add a new measure to an existing goal that already has a measure, select the
checkbox corresponding to the new measure and provide all requested criteria. Issuers do
not have to restate information for measures that are not being changed (e.g., if an issuer is
adding a measure to Goal 2 that already has Measure 2a, the issuer only needs to provide
information in the Measure 2b section).
The issuer should then select the measure(s) to be changed and describe the modifications.
Finally, the issuer should include the rationale for the modified measures.
TIP: The performance target should be a rate (%) or a data point target, NOT a percentage
change.
Step 3: Save the completed Modification Summary Supplement form after verifying
responses have been provided to address all of the required elements and criteria.
Review the form to make sure responses have been provided for all required elements and
criteria. CMS will notify issuers that leave required elements blank and/or do not meet the
evaluation threshold for each element of these deficiencies and will instruct these issuers to
correct and resubmit their Implementation Plan forms during the QHP Application Period.
Save the completed Modification Summary Supplement form as a PDF file. The file name
should follow this naming convention: [5-digit HIOS Issuer ID]_[Issuer Name]_QIS_[MS].
For example, a file named “12345_Issuer ABC_QIS_MS” adheres to the appropriate naming
convention.
If an issuer submits more than one QIS form, the file name for each form should also contain a
numerical identifier: [5-digit HIOS Issuer ID] [Issuer Name]_QIS__[MS]_[#]. For example, if
an issuer submits two Modification Summary Supplement forms, the first file should be named
“12345_Issuer ABC_QIS_MS_1” and the second file should be named “12345_Issuer
ABC_QIS_MS_2.” Issuers MUST make sure that the sequenced forms align with the numbering
on the Progress Report forms as the Modification Summary Supplement form is not a standalone
form and must be associated with the appropriate Progress Report form. All QIS forms must
follow these naming conventions when submitted.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Submit the QIS Form(s)

Issuers will submit their completed QIS forms, along with all other QHP certification
documentation, 59 during the annual QHP Application Period. For the PY2025 QHP Application
Period, the QHP Application submission window for the FFEs is specified in the Qualified
Health Plan (QHP) Data Submission and Certification Timeline for 2025 Plan Year. For the
2025 Plan Year, the QIS forms will be submitted through the accreditation section.
•
•
•

Issuers operating in the FFEs will submit via HIOS.
Issuers operating in FFEs where states perform plan management will submit via SERFF.
Issuers operating in SBEs should contact their Exchanges for specific instructions on QHP
Application submission details, including QIS submission requirements.
TIP: Before an issuer submits the QIS forms, it should use the checklist provided in
Appendix D to confirm its QIS forms’ completeness and verify that the QIS addresses all of
the elements and criteria, especially the six must-pass elements.
TIP: Issuers should not password protect or scan their QIS forms prior to submission via
HIOS or via SERFF. Issuers should submit their QIS forms as fillable-PDF files as opposed
to files that have been scanned. Password protecting QIS submissions prevents CMS from
processing QIS submissions for evaluation. Issuers that submit password protected QIS
forms will be asked to remove password protection and resubmit.

6.1

Submit via HIOS

As noted above, issuers submitting quality improvement strategies for QHPs offered through an
FFE will submit their QIS form(s) through HIOS. Once issuers have typed responses for each
applicable element and criterion into the QIS form(s) and saved a local copy of the completed
form(s), they will need to upload the document(s) to HIOS along with their other QHP
application materials to transmit it to the relevant FFE for evaluation. Issuers operating in FFEs
where the state does not perform plan management will use the Marketplace Plan Management
System (MPMS) to submit QHP data to CMS for review and certification. 60
Issuers operating in FFEs where the state does not perform plan management should follow these
steps to submit their completed Implementation Plan form, Progress Report form, and/or
Modification Summary Supplement form via HIOS 61:
Login steps for accessing the MPMS:
1. Navigate to the CMS Enterprise Portal Login page.

The complete set of QHP Application instructions, templates and materials is available at:
https://www.qhpcertification.cms.gov/s/Home.
60
All users must have a CMS Enterprise Portal Identifier (ID) and HIOS user role to access the MPMS. Users are
required to have a PM Issuer Submitter role to access MPMS. For further details on how to establish a CMS
Enterprise Portal ID, refer to the Enterprise Portal User Guide. For further details on how to request a PM Issuer
Submitter role, please refer to the Identity Management User Guide.
61
Issuers submitting quality improvement strategies for QHPs offered in FFEs where the state performs plan
management will follow a slightly different submission process. See Section 6.2 of this QIS User Guide for further
details.
59

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

2.
3.
4.
5.
6.
7.
8.

Enter User ID and Password into the field.
Select the “I agree to the Terms & Conditions” check box.
Select the green “Login” button.
In My Portal, select the HIOS icon.
Select “Overview.”
Select the “Access HIOS” link.
Select the green “Launch This Module” button for the Marketplace Plan Management
Module.
9. Select “Access the Marketplace Plan Management System module” link.
10. Select the “Accreditation” section of the QHP Application.
11. Select Add Document to Supporting and Justifications Documents and select Quality
Improvement Strategy from the dropdown options.
12. Use the document upload function to upload the completed Implementation Plan form,
Progress Report form, and/or Modification Summary Supplement form to HIOS.
Issuers must label their submissions according to the aforementioned naming convention:
[5-digit HIOS Issuer ID]_[Issuer Name]_QIS_[IP, PR or MS], for single submissions and
[5-digit HIOS Issuer ID]_[Issuer Name]_QIS_[IP, PR or MS]_[#], for multiple submissions.
TIP: For help accessing HIOS, or for technical assistance related to QIS form submission
in HIOS, please contact the Marketplace Service Desk (MSD) at [email protected]
or 1-855-CMS-1515.

6.2

Submit via SERFF

Issuers submitting quality improvement strategies for QHPs offered in FFEs where the state
performs plan management follow a slightly different submission process. These issuers submit
their QIS forms through SERFF. Once submitted, these issuers’ QIS forms are transmitted to the
state and the FFEs for joint evaluation.
Issuers operating in FFEs where the state performs plan management should follow these steps to
submit their completed QIS forms to the Exchange via SERFF:
Step 1: Open a web browser and go to the SERFF home page: http://www.serff.com.
Step 2: Enter the user’s credentials (i.e., user name and password) to access SERFF.
Step 3: Upload the completed QIS form (in Adobe Acrobat PDF format) to SERFF.
Issuers must label their submissions according to the aforementioned naming conventions:
[5-digit HIOS Issuer ID]_[Issuer Name]_QIS_[IP, PR or MS], for single submissions and
[5-digit HIOS Issuer ID]_[Issuer Name]_QIS_[IP, PR or MS]_[#], for multiple submissions.
TIP: For information on uploading forms and supporting documents in SERFF, please visit
the SERFF website. Direct questions about SERFF to the SERFF Help Desk at 1-816-7838990 or via email at [email protected].

pg. 54

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Address Incomplete or Deficient QIS Submissions

CMS will evaluate issuers’ submissions to determine whether their quality improvement
strategies meet the QIS requirements (see Volume I, Section 5). The following steps provide
information about what issuers must do if CMS determines that their submissions are incomplete
and/or do not meet the QIS requirements. 62

7.1

Addressing Deficiencies During the Current QHP Application Period

During the QHP Application Period, CMS assesses issuers’ QIS submissions for completeness.
If an issuer’s submission contains blank fields or is missing information, CMS sends required
corrections to the issuer. The following steps provide information about what issuers should do if
they are notified of required corrections during the QHP Application Period.
Step 1: Review results to identify any deficiencies related to the QIS.
The review results will specify any QIS form that is missing information, submitted in the
incorrect format, missing required parts, or not submitted at all.
Step 2: Open the local copy of the issuer’s saved QIS form.
Use the final version that was previously uploaded to HIOS or SERFF and submitted for
evaluation.
Step 3: Edit the responses to the elements and/or criteria that were identified in the
review results as requiring attention.
The issuer should provide responses or make corrections to the elements and criteria CMS
indicated were missing information. The new responses should address the identified
deficiencies by providing additional information or including missing information as directed by
the review results.
The issuer should not make any changes to their response(s) for elements and/or criteria that
CMS DID NOT specifically identify in the review results.
The issuer should update the Submission Date field at the top of the form.
Step 4: Save a local copy of the revised QIS form.
Make sure to save the local copy of the revised form and make it available to the appropriate
issuer staff.
Step 5: Upload the revised QIS form(s) to HIOS or SERFF (as appropriate).
Follow the steps provided in Section 5 above to submit the revised forms to CMS and the state
(if applicable). Issuers operating in FFEs where the state performs plan management should
submit via SERFF; for all other FFE states, issuers should submit via HIOS in the Marketplace
Plan Management System (MPMS).
Issuers offering coverage in FFEs where the state performs plan management should contact the applicable state
regulator(s) for additional details on the state process for evaluating QIS submissions. Issuers offering coverage in
SBEs should contact the applicable Exchange for details on the process for evaluating QIS submissions.

pg. 55

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

7.2

Addressing Concerns After the QHP Application Period

CMS begins evaluations of complete QIS submissions after the close of the 2025 QHP
Application Period. CMS will communicate evaluation results for QIS submissions for the 2025
Plan Year to issuers in the late fall of 2024. CMS will include in these communications
directions on how to address concerns (e.g., remaining deficiencies or missing information) after
the QHP Application Period.

pg. 56

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Appendices

pg. 57

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Appendix A. Excerpts of Relevant Statutory and Regulatory Citations
Exhibit 18: Patient Protection and Affordable Care Act, 42 U.S.C. Sec. 18031 (March 23, 2010)
Topic

Provisions

Citation

QHP certification
standards for
quality
improvement
strategies

(c) RESPONSIBILITIES OF THE SECRETARY.—
(1) IN GENERAL.—The Secretary shall, by regulation, establish
criteria for the certification of health plans as qualified health plans.
Such criteria shall require that, to be certified, a plan shall, at a
minimum—
(E) implement a quality improvement strategy described in
subsection (g)(1).

Section 1311(c)(1)(E)

Exchange
standards for
quality
improvement
strategies

(g) REWARDING QUALITY THROUGH MARKET-BASED
INCENTIVES —
(1) STRATEGY DESCRIBED — A strategy described in this
paragraph is a payment structure that provides increased
reimbursement or other incentives for—
(A) improving health outcomes through the implementation of
activities that shall include quality reporting, effective case
management, care coordination, chronic disease management,
medication and care compliance initiatives, including through the
use of the medical home model, for treatment or services under the
plan or coverage;
(B) the implementation of activities to prevent hospital
readmissions through a comprehensive program for hospital
discharge that includes patient-centered education and counseling,
comprehensive discharge planning, and post discharge
reinforcement by an appropriate health care professional;
(C) the implementation of activities to improve patient safety and
reduce medical errors through the appropriate use of best clinical
practices, evidence-based medicine, and health information
technology under the plan or coverage;
(D) the implementation of wellness and health promotion activities;
and
(E) the implementation of activities to reduce health and health
care disparities, including through the use of language services,
community outreach, and cultural competency trainings.
(2) GUIDELINES — The Secretary, in consultation with experts in
health care quality and stakeholders, shall develop guidelines
concerning the matters described in paragraph (1).
(3) REQUIREMENTS — The guidelines developed under
paragraph (2) shall require the periodic reporting to the applicable
Exchange of the activities that a qualified health plan has
conducted to implement a strategy described in paragraph (1).

Section 1311(g)

Exhibit 19: Patient Protection and Affordable Care Act; Establishment of Exchanges and Qualified Health
Plans; Exchange Standards for Employers, Final Rule, 77 Fed. Reg. 18310-18475 (March 27, 2012)
Topic

Provisions

Citation

Exchange
oversight
responsibilities
for quality
activities

(d) Quality activities. The Exchange must evaluate quality
improvement strategies and oversee implementation of enrollee
satisfaction surveys, assessment and ratings of health care quality
and outcomes, information disclosures, and data reporting in
accordance with sections 1311(c)(1), 1311(c)(3), and 1311(c)(4) of
the Patient Protection and Affordable Care Act.

45 CFR § 155.200(d)
Functions of an
Exchange

pg. 58

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Exhibit 20: Patient Protection and Affordable Care Act; Exchange and Insurance Market Standards
for 2015 and Beyond, Final Rule, 79 Fed. Reg. 30240-30353 (May 27, 2014)
Topic

Provisions

Citation

QHP issuer
participation
standards

(a) General requirement. In order to participate in an Exchange, a
health insurance issuer must have in effect a certification issued or
recognized by the Exchange to demonstrate that each health plan
it offers in the Exchange is a QHP.
(b) QHP issuer requirement. A QHP issuer must—
(5) Implement and report on a quality improvement strategy or
strategies described in section 1311(c)(1)(E) of the Patient
Protection and Affordable Care Act consistent with the standards of
section 1311(g) of the Patient Protection and Affordable Care Act,
disclose and report information on health care quality and
outcomes described in sections 1311(c)(1)(H), (c)(1)(I), and (c)(3)
of the Patient Protection and Affordable Care Act, and implement
appropriate enrollee satisfaction surveys consistent with section
1311(c)(4) of the Patient Protection and Affordable Care Act;
(h) As a condition of certification of a QHP, an issuer must attest
that it will comply with all QHP operational requirements described
in subparts D, E, H, K, L, and M of this part.

45 CFR § 156.200(a),
(b)(5),(h) QHP issuer
participation
standards

Exchange QHP
certification
standards

a) Definition. The following definition applies in this subpart: Multistate Plan means a health plan that is offered in accordance with
section 1334 of the Patient Protection and Affordable Care Act.
(b) General requirement. The Exchange must offer only health
plans which have in effect a certification issued or are recognized
as plans deemed certified for participation in an Exchange as a
QHP, unless specifically provided for otherwise.
(c) General certification criteria. The Exchange may certify a health
plan as a QHP in the Exchange if—
(1) The health insurance issuer provides evidence during the
certification process in §155.1010 that it complies with the
minimum certification requirements outlined in subpart C of part
156, as applicable; and
(2) The Exchange determines that making the health plan available
is in the interest of the qualified individuals and qualified
employers, except that the Exchange must not exclude a health
plan—
(i) On the basis that such plan is a fee-for-service plan;
(ii) Through the imposition of premium price controls; or
(iii) On the basis that the health plan provides treatments
necessary to prevent patients' deaths in circumstances the
Exchange determines are inappropriate or too costly.

45 CFR § 155.1000,
Certification
standards for QHPs

pg. 59

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Exhibit 21: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters
for 2016, Final Rule, 80 Fed. Reg. 10750-10877 (February 27, 2015)
Topic

Provisions

Citation

Quality
improvement
strategy standards

(a) General requirement. A QHP issuer participating in an
Exchange for 2 or more consecutive years must implement and
report on a quality improvement strategy including a payment
structure that provides increased reimbursement or other marketbased incentives in accordance with the health care topic areas in
section 1311(g)(1) of the Patient Protection and Affordable Care
Act, for each QHP offered in an Exchange, consistent with the
guidelines developed by HHS under section 1311(g) of the Patient
Protection and Affordable Care Act.
(b) Data requirement. A QHP issuer must submit data that has
been validated in a manner and time frame specified by the
Exchange to support the evaluation of quality improvement
strategies in accordance with 155.200(d) of this subchapter.
(c) Timeline. A QHP issuer must submit data annually to evaluate
compliance with the standards for a quality improvement strategy
in accordance with paragraph (a) of this section, in a manner and
time frame specified by the Exchange.

45 CFR §
156.1130(a)-(c),
Quality Improvement
Strategy

Exhibit 22: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters
for 2023, Final Rule, 87 Fed. Reg. 27208-27393 (May 6, 2022)
Topic

Provisions

Citation

Quality
improvement
strategy standards

As stated in the HHS Notice of Benefit and Payment Parameters
for 2023 final rule ,QHP issuers are required to address health
and health care disparities as a specific topic area within their
QIS, in addition to at least one other topic area described in
section 1311(g)(1) of the PPACA. This expansion of the QIS
standards aligns with health equity efforts across Federal
government policies and programs; however, we did not amend
the regulatory text outlined in § 156.1130.

45 CFR § 156.1130,
Quality Standards:
Quality Improvement
Strategy

pg. 60

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Appendix B. QIS Forms Pre-Submission Checklist
The checklist shown as Exhibit 23 is intended to help issuers verify the completeness of their
QIS forms, confirm that their responses address all of the elements and criteria―especially the
must-pass elements―and guide them through the QIS submission process.
Exhibit 23: Implementation Plan Form and Progress Report Form Pre-Submission Checklist

QIS FORMS PRE-SUBMISSION CHECKLIST
A. PREPARATION
☐

Review the applicable regulations, the entire 2025 QIS Technical Guidance and QIS User Guide, and the relevant
sections of the 2025 Letter to Issuers.

☐

Print or save each QIS-related document listed on the QHP Application website.

☐

Download and save a local copy of the fillable PDF of the QIS forms appropriate to the issuer’s situation (see
Appendix D for more information).

B. COMPLETE THE IMPLEMENTATION PLAN FORM
☐ Enable JavaScript in the fillable PDF form before you enter your QIS information.
☐

Complete the QIS Submission Type section (Part A) by checking the applicable Type of QIS Submission.

☐

In Elements 3−6 in Part B, use the same information that was included elsewhere in the QHP Application templates.

☐

Complete all elements in Part B: Issuer Information, in the Background Information section.

☐

Complete Part C: Data Sources Used for Problem Identification and Monitoring Progress in the Background
Information section.

☐ Complete all of the elements and criteria in Part D: QIS Summary in the Implementation Plan form.
☐
☐

Complete all of the elements and criteria in Part E: QIS Requirements in the Implementation Plan form.
Confirm that you have provided responses for all required elements—including must-pass elements—and criteria in
all parts of the form, either by providing QIS information or by selecting “Not Applicable.”

☐ Confirm that you were consistent in your answers across all elements and criteria.

C. COMPLETE THE PROGRESS REPORT FORM
☐ Enable JavaScript in the fillable PDF form before you enter your QIS information.
☐Complete Part A: QIS Submission Type by checking the applicable Type of QIS Submission.
☐Complete all elements in Part B: Issuer Information in the Background Information section.
☐In Elements 2–5 of Part B, use the same information that was included elsewhere in the QHP Application templates.
☐Complete all of the required elements and criteria in Part C: Progress Report Summary.
☐ Confirm that you have provided responses for all required elements—including must-pass elements—and criteria in all

parts of the form, either by providing QIS information or by selecting “Not Applicable” in elements or criteria where this
is an option.

☐Confirm that you were consistent in your answers across all elements and criteria.

pg. 61

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

D. COMPLETE THE MODIFICATION SUMMARY SUPPLEMENT FORM
☐ Enable JavaScript in the fillable PDF form before you enter your QIS information.
☐Complete Part A: QIS Submission by checking the applicable Type of QIS Submission.
☐Complete all elements in Part B: Issuer Information in the Background Information section.
☐Complete the required elements and criteria in Part C: Modification Summary.
☐ Confirm that you have provided responses for all required elements—including must-pass elements—and criteria in all

parts of the form, either by providing QIS information or by selecting “Not Applicable” in elements or criteria where this
is an option.

☐Confirm that you were consistent in your answers across all elements and criteria.

E. SUBMIT THE FORM(S)
☐

Save a local copy of the form(s) using the appropriate file naming convention, either [5-digit HIOS Issuer ID]_[Issuer
Legal Name]-_QIS_[IP or PR or MS] or [5-digit HIOS Issuer ID]-_[Issuer Legal Name]_QIS_[IP or PR or MS]_[#]. Do not
password protect or flatten the completed fillable PDF form.

☐

Upload the completed copy of the QIS form(s) to HIOS or SERFF, as appropriate, for submission to the FFEs. For
coverage offered through an SBE, issuers should follow the guidance provided by the applicable Exchange.

☐

Share your QIS submission with staff who are responsible for the QIS so they may refer to it throughout the year as
needed and reference it during the next QHP Application Period.

☐

Verify that each applicable QHP offered by the issuer through an Exchange is covered by a QIS; submit additional QIS
forms, as necessary.

pg. 62

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Appendix C. Elements and Criteria
Exhibit 24: QIS Implementation Plan Form Elements and Criteria

QIS Implementation Plan Form

Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Change Requires
Discontinuation
Selection in Element
1 63

Part A
1

Type of QIS Submission
None
Select the option that describes the type
of QIS submission and follow the
instructions to complete the submission.

This element is
required but will
not be scored.

None

Not Applicable

Targets All QHPs and Product Types 2a – Indicate if this QIS is applicable to This element is
all eligible QHPs the issuer offers or is required but will
Offered Through an Exchange
applying to offer through the Exchanges, not be scored.
or to a subset of eligible QHPs. If
“Subset of QHPs” is selected, an
additional QIS Implementation Plan(s)
(Parts D and E of this form) must be
submitted for eligible QHPs not covered
by this QIS.
2b – Select the relevant product types to
which the QIS applies. Check all that
apply.

None

Not Applicable

Issuer Legal Name

None

This element is
required but will
not be scored.

None

Not Applicable

Company Legal Name

None

This element is
required but will
not be scored.

None

Not Applicable

Part B

This column indicates whether a change to a given element/criterion from a previous QIS requires selecting “New QIS after Discontinuing a QIS Submitted
during a Prior Qualified Health Plan (QHP) Application Period” or “New QIS with No Previous QIS Submission” in Element 1 of the Implementation Plan
form. Issuers with no previous QIS submission must select “New QIS with No Previous QIS Submission” in Element 1. A “new QIS” is defined as a QIS that
has not been previously submitted to an Exchange.

pg. 63

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Implementation Plan Form

Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Change Requires
Discontinuation
Selection in Element
1 63

HIOS Issuer ID

None

This element is
required but will
not be scored.

None

Not Applicable

Issuer State

None

This element is
required but will
not be scored.

None

Not Applicable

QIS Primary Contact’s Name

None

This element is
required but will
not be scored.

None

Not Applicable

QIS Primary Contact’s Title

None

This element is
required but will
not be scored.

None

Not Applicable

QIS Primary Contact’s Phone

None

This element is
required but will
not be scored.

None

Not Applicable

QIS Primary Contact’s Email

None

This element is
required but will
not be scored.

None

Not Applicable

QIS Secondary Contact’s Name

None

This element is
required but will
not be scored.

None

Not Applicable

QIS Secondary Contact’s Title

None

This element is
required but will
not be scored.

None

Not Applicable

QIS Secondary Contact’s Phone

None

This element is
required but will
not be scored.

None

Not Applicable

QIS Secondary Contact’s Email

None

This element is
required but will
not be scored.

None

Not Applicable

Date Issuer Began Offering Coverage None
Through the Exchange

This element is
required but will
not be scored.

None

Not Applicable

pg. 64

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Implementation Plan Form

Element #
16

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Change Requires
Discontinuation
Selection in Element
1 63

Current Payment Model(s)
None
Description
Select the category(ies) of payment
models that are used by the issuer
across the applicable Exchange product
line. Provide the percentage of
payments in each payment model
category used by the issuer across the
applicable Exchange product line. The
total percentage of payments across all
four payment model types should equal
approximately 100%. These
percentages can be estimates and do
not need to be exact figures. Issuers
may update this information from year to
year, as needed.

This element is
required but will
not be scored.

None

Data Sources
None
Indicate the data sources used for
identifying QHP enrollee population
needs and supporting the QIS rationale
(see Element 23). Check all that apply.

This element is
required but will
not be scored.

100 characters if Not Applicable
“Other” is
selected

QIS Title
Provide a short title for the QIS.

This element is
required but will
not be scored.

200 characters

Not Applicable

Part C
17

Part D
18

None

Not Applicable

pg. 65

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Implementation Plan Form

Element #
19

Element Name and Explanation
(if applicable)
QIS Description
None
Provide a brief summary description of
the QIS. The description must include
the market-based incentive type(s) and
topic area(s) (see Elements 21 and 22).
Is the QIS described above part of a
mandatory state initiative?
Is the QIS submission a strategy that
the issuer currently has in place for its
Exchange product line and/or for other
product lines?
If "Yes” was checked for either/both of
the above, please describe the state
initiative and/or current issuer strategy.

Criteria

Scoring
This element is
required but will
not be scored.

Response
Character Limit

Change Requires
Discontinuation
Selection in Element
1 63

1,000 characters Not Applicable
for the brief
summary
description;
1,000 characters
for a description
of initiatives

pg. 66

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Implementation Plan Form

Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Change Requires
Discontinuation
Selection in Element
1 63

Part E
20

QIS Goals
None
Describe the overall goal(s) of the QIS
(no more than two). The topic area(s)
selected in Element 22 and the
measure(s) described in Element 25
should be linked to these goals.
Note: The topic area(s) selected in
Element 22 and the measure(s)
described in Element 25 should be
linked to these goals. Please do not
include specific performance targets or
goals tied to a specific calendar year or
plan year because this Implementation
Plan Form will remain on file and
references to specific years or
performance targets will become
outdated over time.

This element is
required but will
not be scored.

Market-based Incentive Type(s)
None
Select the sub-type of market-based
incentive(s) the QIS includes. Check all
that apply. If either “In-kind incentives,”
“Other provider market-based
incentives,” or “Other enrollee marketbased incentives” is selected, provide a
brief description in the space provided.

This element will 500 characters
be scored;
per text box
Element 21 is a
must-pass
element.

500 characters
per text box

Not Applicable

Yes, issuer must select
“New QIS After
Discontinuing a QIS
Submitted During a Prior
QHP Application Period”
and submit two forms: A
Progress Report to close
out its current QIS and a
new Implementation
Plan.

pg. 67

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Implementation Plan Form

Element #
22

Element Name and Explanation
(if applicable)
Topic Area Selection
Select the topic area(s) this QIS
addresses, as defined in the Patient
Protection and Affordable Care Act.
Check each topic area that applies.

Criteria
None

Scoring

Response
Character Limit

This element will 500 characters
be scored;
Element 22 is a
must-pass
element.

Change Requires
Discontinuation
Selection in Element
1 63
Not Applicable

If the “Reduce health and health care
disparities” Topic Area is selected, what
population(s) does the QIS address?
23

Rationale for QIS
None
23 – Provide (1) a rationale for the QIS
that describes the issuer’s current QHP
enrollee population(s) and (2) how the
QIS will address the needs of the
current QHP enrollee population(s).

This element will 1,500 characters Not Applicable
be scored;
Element 23 is a
must-pass
element.

Activity(ies) That Will Be Conducted
to Implement the QIS

This element will 1,500 characters Not Applicable
be scored;
per criterion
Element 24 is a
must-pass
element.

24a – List the activities that will be
implemented to achieve the identified
goals in Element 20.
24b – Describe how the activities listed
in Criterion 24a relate to the marketbased incentive(s) selected in Element
21.
24c – Describe how the activities listed
in Criterion 24a relate to the selected
topic area(s) selected in Element 22.

pg. 68

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Implementation Plan Form

Element #
25

Element Name and Explanation
(if applicable)
Goal(s), Measure(s), and
Performance Target(s) to Monitor QIS
Progress
For each goal, identify at least one (but
no more than two) primary measure(s)
used to track progress toward meeting
the goal. For each measure identified,
address the criteria in the criteria
column to the right.

Criteria

Scoring

25a, 25f, 25k, 25p – Provide the name
of the measure; narrative description of
the measure numerator and
denominator or how the data point was
calculated; whether the measure is
consensus-based entity (CBE)endorsed; CBE ID, if applicable (CBEendorsed measures are not required); if
CBE-endorsed, whether the measure
specifications were modified.
25b, 25g, 25l, 25q – Describe how the
measure supports the tracking of
performance related to the goal.
25c, 25h, 25m, 25r – Baseline
Assessment. Provide the baseline
results by calculating the rate or
providing the applicable data point. If the
measure is a rate, provide the
associated numerator and denominator
and the calculated rate. Note: The
numerator and denominator should
calculate to the rate provided. If the
measure is not a rate but another data
point, enter the applicable number in the
space provided.
25d, 25i, 25n, 25s – Provide the
baseline performance period (i.e., month
and year when data collection began
and ended) covered by the baseline
data assessment provided in Criterion
25 of the Implementation Plan on file.
25e, 25j, 25o, 25t – Provide the
numerical value performance target for
this measure (i.e., the target rate or data
point the QIS intends to achieve). Note:
This entry should NOT be a percentage
change but a numerical value.

This element will
be scored;
Element 25 is a
must-pass
element.

Response
Character Limit

Change Requires
Discontinuation
Selection in Element
1 63

500 characters Not Applicable
per measure
description;
1,000 characters
per description
of how the
measure
supports
tracking of goals

pg. 69

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Implementation Plan Form

Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Change Requires
Discontinuation
Selection in Element
1 63

Timeline for Implementing the QIS

26a – QIS initiation/start date.
26b – Describe the milestone(s) and
provide the date(s) for each milestone
(i.e., when activities described in
Element 24 will be implemented). At
least one milestone is required.

This element will 100-character
Not Applicable
be scored. Both limit per
criteria must be milestone in 26b
completed.

Risk Assessment

27a – List all known or anticipated
barriers to implementing QIS Activities.
If no barriers were identified, describe
how you assessed risk in the box below.
If barriers were identified above, this box
should be left blank.
27b – Describe the mitigation activities
that will be incorporated to address each
barrier identified in Criterion 27a. If there
were no barriers identified, this box
should be left blank.

This element will
be scored.
Element 27 is a
must-pass
element.

750-character
Not Applicable
limit per text box
in 27a; 1,500
character limit
for 27b

pg. 70

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Exhibit 25: QIS Progress Report Form Elements and Criteria

QIS Progress Report Form
Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Part A
1

Type of QIS Submission
None
Select the option that describes the type
of QIS submission and follow the
instructions to complete the submission.

This element is
None
required but will not
be scored.

QIS Title
Restate the short title for the QIS.
Part B
2

Issuer Legal Name

None

This element is
None
required but will not
be scored.

Company Legal Name

None

This element is
None
required but will not
be scored.

HIOS Issuer ID

None

This element is
None
required but will not
be scored.

Issuer State

None

This element is
None
required but will not
be scored.

QIS Primary Contact’s Name

None

This element is
None
required but will not
be scored.

QIS Primary Contact’s Title

None

This element is
None
required but will not
be scored.

QIS Primary Contact’s Phone

None

This element is
None
required but will not
be scored.

QIS Primary Contact’s Email

None

This element is
None
required but will not
be scored.

pg. 71

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Progress Report Form
Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

QIS Secondary Contact’s Name

None

This element is
None
required but will not
be scored.

QIS Secondary Contact’s Title

None

This element is
None
required but will not
be scored.

QIS Secondary Contact’s Phone

None

This element is
None
required but will not
be scored.

QIS Secondary Contact’s Email

None

This element is
None
required but will not
be scored.

Date Issuer Began Offering Coverage None
Through the Exchange

This element is
None
required but will not
be scored.

Current Payment Model(s) Description None
Select the category(ies) of payment
models that are used by the issuer
across the applicable Exchange product
line. Provide the percentage of payments
in each payment model category used by
the issuer across the applicable
Exchange product line. The total
percentage of payments across all four
payment model types should equal
approximately 100%. These percentages
can be estimates and do not need to be
exact figures. Issuers may update this
information from year to year, as
needed.

This element is
None
required but will not
be scored.

Analyze Progress Using Baseline
Data, as Documented in the
Implementation Plan
Restate the Goal(s) identified in Element
20 of the Implementation Plan on file or

This element will be 500 characters per
scored; Element 16 goal
is a must-pass
element.

Part C
16

16a, 16h, 16o, 16v – Restate measure name(s) from
Element 20 of the Implementation Plan on file or
Element 8 of the Modification Summary Supplement
form on file, if applicable, and provide the 4-digit
CBE-ID number.

pg. 72

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Progress Report Form
Element #

Element Name and Explanation
(if applicable)
Element 8 of the Modification Summary
Supplement form on file, if applicable.

Criteria
16b, 16i, 16p, 16w – Restate the baseline results from
Element 20 of the Implementation Plan on file or
Element 8 of the Modification Summary Supplement
form on file, if applicable, by calculating the rate or
providing the applicable data point. If the measure is a
rate, provide the associated numerator and
denominator and the calculated rate. Note: The
numerator and denominator should calculate to the rate
provided. If the measure is not a rate but another data
point, enter the applicable number in the space
provided.
16c, 16j, 16q, 16x – Provide the baseline performance
period (i.e., the month and year when data collection
began and ended) covered by the baseline assessment
from Element 25 of the Implementation Plan on file or
Element 8 of the Modification Summary Supplement
form on file, if applicable.
16d, 16k, 16r, 16y – Provide the Progress Report
results by calculating the rate or providing the
applicable data point. If the measure is a rate, provide
the associated numerator and denominator and the
calculated rate. Note: The numerator and denominator
should calculate to the rate provided. If the measure is
not a rate but another data point, enter the applicable
number in the space provided.
16e, 16l, 16s, 16z – Provide the Progress Report
performance period (i.e., month and year when data
collection began and ended) covered by the progress
report assessment.
16f, 16m, 16t, 16aa – Restate the numerical value
performance target for the measure (i.e., the target rate
or data point the QIS intends to achieve) from Element
25 of the Implementation Plan on file or Element 8 of
the Modification Summary Supplement form on file, if
applicable. Note: This entry should be a rate (%) or a
data point target, NOT a percentage change.
16g, 16n, 16u, 16bb – Was the performance target
achieved?

Scoring

Response
Character Limit

pg. 73

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Progress Report Form
Element #
17

Element Name and Explanation
(if applicable)
Summary of Progress

Criteria
17a – Please provide a summary of progress covering
the following details: (1) Indicate why progress was or
was not made toward the performance target(s)
documented in Element 25 of the QIS Implementation
Plan on file or Element 8 of the Modification Summary
Supplement form on file, if applicable, and (2) Include a
description of activities that led to the outcome. Note:
Regardless of if you made progress toward the
performance target(s), you will be required to describe
any barriers encountered in Criterion 18a and any
problems meeting timelines in Criterion 18b.
17b – If the issuer selected “Progress Report
Closeout Form” in Element 1 of this Progress Report
form, provide the rationale for discontinuing the QIS.
17c – If the issuer received an “Interim Meets” scoring
designation during the previous evaluation period and
was instructed to address the deficiencies in their
subsequent Plan Year submission, please indicate
which elements and/or criteria you updated based on
the QIS evaluation results and describe the changes.
If the scenarios described in 17b or 17c do not apply,
issuers should leave these fields blank.

Scoring

Response
Character Limit

This element will be 1,000 characters per
scored; Element 17 criterion
is a must-pass
element.

pg. 74

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Progress Report Form
Element #
18

Element Name and Explanation
(if applicable)
Barriers and Mitigation Activities

Criteria

Scoring

Response
Character Limit

18a – Were barriers encountered in implementing the
This element will be 1,500 characters per
QIS? If “Yes,” describe: (1) the barriers and (2) the
scored. Both criteria criterion
mitigation activities implemented (including the results must be completed.
of such activities) to address each barrier. Note: If your
description of activities in Criterion 17a includes barriers
to implementing the QIS, you are still required to
complete Criterion 18a and elaborate on those barriers
and any other barriers to implementing the QIS, if
applicable, by providing the below information.
18b – Were there problems meeting timelines as
indicated in Element 26 of the QIS Implementation Plan
on file? If “Yes,” describe: (1) the problems in meeting
timelines, and (2) the mitigation activities implemented
to address each problem in meeting the timeline. Note:
If your description of activities in Criterion 17a includes
problems meeting timelines, you are still required to
complete Criterion 18b and elaborate on those
problems and any other problems in meeting timelines,
if applicable, by providing the below information.

Exhibit 26: QIS Modification Summary Supplement Form Elements and Criteria

QIS Modification Summary Supplement Form
Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Part A
1

Type of QIS Submission
None
Select the option that describes the
type of QIS submission and follow the
instructions to complete the submission.

This element is
None
required but will not
be scored.

QIS Title
Restate the short title for the QIS.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Modification Summary Supplement Form
Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Part B
2

Issuer Legal Name

None

This element is
None
required but will not
be scored.

HIOS Issuer ID

None

This element is
None
required but will not
be scored.

Issuer State

None

This element is
None
required but will not
be scored.

QIS Primary Contact’s Name

None

This element is
None
required but will not
be scored.

QIS Primary Contact’s Email

None

This element is
None
required but will not
be scored.

QIS Primary Contact’s Phone

None

This element is
None
required but will not
be scored.

pg. 76

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

QIS Modification Summary Supplement Form
Element #

Element Name and Explanation
(if applicable)

Criteria

Scoring

Response
Character Limit

Part C
8

Modifying Product Types, Topic
Areas, Goals, Activities, and
Measures or Associated
Performance Targets
Complete the following section
regarding modifications to the QIS for
the upcoming plan year

8a - Which component(s) of your QIS are you modifying for the
upcoming plan year? (check boxes for product types, goals,
activities, measures, and performance targets)
8b - Modifying QIS Product Types: For product type changes,
indicate whether you are adding and/or removing any product
types to the QIS originally listed in Criterion 2b of your
Implementation Plan on file. Select all that apply.
8c - Modifying QIS Topic Areas: For topic area(s) changes,
indicate whether you are adding and/or removing any product
types to the QIS originally listed in Element 22 of your
Implementation Plan on file. Select all that apply.
8d - Modifying QIS Goals: For modified Goal(s), indicate which
Goal(s) you are modifying and state the new Goal(s) in the
space provided below:
8e - Modifying QIS Activities: If you are modifying QIS activities,
describe them here. Provide a rationale for the modification(s)
8f - Modifying QIS Measures or Associated Performance
Targets: For modified Measures or Associated Performance
Targets, indicate which Measure(s) you are modifying and state
the new Measure(s) and Performance Target(s). Describe
modification (e.g., remove measure, change measure or
measure specifications, change target, add new measure).

This element will be 500 characters
scored; Element 8 per criterion
is a must-pass
element.

pg. 77

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Appendix D. Scenarios for Form Completion Based on Type of QIS
Submission
Exhibit 27 describes common situations for issuers seeking to comply with the QIS requirements
and provides information about what sections of the QIS forms they should complete based on
the type of QIS submission.
The “Type of QIS Submission” column corresponds to the check box selections found in Part A
(QIS Submission Type) of the QIS forms. Issuers that meet the QIS participation criteria must
complete Part A of the applicable QIS form(s) annually, in addition to any other required
sections.
Exhibit 27: Scenarios for Form Completion Based on Type of QIS Submission
Issuer and Prior QIS
Submission History

Type of QIS Submission
New QIS with No
Previous QIS
Submission

New QIS After
Discontinuing a QIS
Submitted During a
Prior QHP Application
Period






QIS Form Sections To Be Completed

The issuer has offered QHPs
through an Exchange for at least
two consecutive years AND
Has not previously submitted an
Implementation Plan form or
intends to create a new QIS that is
not replacing an existing one 64



The issuer has previously
submitted an Implementation Plan
form and a Progress Report form
based upon that Plan AND
The issuer intends to discontinue
its previous strategy to implement
a new QIS (e.g., one with a
different market-based incentive
than its previous QIS)
The issuer has previously
submitted two Modification
Summary Supplement forms to
change the same QIS and intends
to modify that strategy in the 2025
Plan Year for a third time.



Complete the QIS Submission Type
and Background Information sections
(Parts A, B and C) of the
Implementation Plan form AND
Complete the QIS Implementation Plan
section (Parts D and E) of the
Implementation Plan form
Complete two forms – (1) an
Implementation Plan form and (2)
Progress Report form
Complete a new Implementation Plan
form to create the new QIS:
- Complete the QIS Submission Type
and Background Information
sections (Parts A, B and C)
- Complete the QIS Implementation
Plan section (Parts D and E)
Complete a Progress Report Closeout
form to discontinue the existing QIS:
- Complete the QIS Submission Type
and Background sections (Parts A
and B)
- Complete the QIS Progress Report
Summary (Part C)

The issuer must not have submitted an Implementation Plan for QHPs that will be covered by the QIS for which
the issuer is currently completing the QIS form. If a subset of an issuer’s QHPs is covered by a different QIS, then
the issuer may have previously submitted a QIS for those plans, but may still select “New QIS with No Previous
QIS Submission” as long as the current QIS addresses an entirely different subset of QHPs from those covered by
the previously submitted QIS. If an issuer submitted a QIS, then was no longer required to submit a QIS, and now
meets the QIS requirements again, it should select “New QIS with No Previous QIS Submission” in Element 1.

pg. 78

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Issuer and Prior QIS
Submission History

Type of QIS Submission
Progress Report (i.e.,
Continuing an existing
QIS with no changes or
no changes that warrant
a modification)



Progress Report
Closeout Form



Continuing QIS with
Modifications (i.e.,
Continuing a QIS
Submitted During a
Prior Application Period
and Making Changes
That Warrant a
Modification)

The issuer previously submitted an
Implementation Plan form AND
Will continue its existing QIS 65

QIS Form Sections To Be Completed



Complete the QIS Submission Type
and Background Information sections
(Parts A and B) of the Progress Report
form AND
Complete the QIS Progress Report
Summary (Part C) of the Progress
Report form

The issuer has previously
submitted an Implementation Plan
form AND
The issuer intends to discontinue
its existing QIS to implement a
new QIS (i.e., one with a different
market-based incentive than its
previous QIS).

Complete two forms – (1) Update the
Background Section (Part B of the
Progress Report form) AND (2)
Complete the QIS Progress Report
Summary (Part C)
 See also “New QIS After Discontinuing
a QIS Submitted during a Prior QHP
Application Period”

The issuer has previously
submitted an Implementation Plan
form and is reporting on progress
AND
Intends to make changes that
warrant a modification to its
existing QIS (i.e., changes to topic
areas, goals, activities, measures,
performance targets, or product
types) and the issuer has not
previously submitted two
Modification Summary Supplement
forms to change the same QIS.



Complete the QIS Submission Type
and Background sections (Parts A and
B) of the Modification Summary
Supplement form
Complete the QIS Modification
Summary section (Part C) of the
Modification Summary Supplement
form

Changes that warrant a modification to the QIS must be captured through submission of the Modification
Summary Supplement form.

pg. 79

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Appendix E. Market-Based Incentive Examples
Exhibit 28 and Exhibit 29 provide definitions and examples of provider and enrollee marketbased incentive strategy types, respectively. The examples are demonstrative of the type of
market-based incentives an issuer’s QIS should include, but the list is not exhaustive. Issuers
should refer to these tables when responding to Element 21 in the Implementation Plan form.
Exhibit 28: Examples and Definitions of Market-Based Incentives for Providers
Provider Market-Based
Incentive Examples

Market-Based Incentive Type Definition

Increased Reimbursement

Providers receive a higher payment based on whether they meet certain quality
performance targets. If providers meet performance targets, they receive the
maximum eligible payment, but if they do not meet all of the performance targets,
they receive only a portion of the maximum payment they are eligible to receive.

Bonus Payments

An additional incentive payment (beyond regular FFS payments) to providers,
contingent on meeting certain measure-based performance targets.

In-Kind Incentives

In-kind incentives do not use a direct financial payment. In-kind incentives are the
provision of non-financial resources for the purpose of supporting quality
improvement. These incentives may include, but are not limited to, in-office nurses
or physician extenders, staffing support to conduct care coordination, technical
support for data collection, 66 and/or health IT implementation.

Exhibit 29: Examples and Definitions of Market-Based Incentives for Exchange Enrollees
QHP Enrollee MarketBased Incentive Examples

Market-Based Incentive Type Definition

Premium Credit

A reduction in the enrollee’s premium (i.e., the monthly, quarterly, or yearly amount
a member pays for health insurance coverage).

Co-payment Reduction or
Waiver

A decrease in the co-payment or waiver of the entire co-payment amount an
enrollee would pay for a covered health care service, usually at the time of service.

Co-insurance Reduction

A decrease in co-insurance. Co-insurance is typically calculated as a percentage
(e.g., 20%) of the allowed amount for the covered service, not including the
deductible.

Cash or Cash Equivalents

The QHP pays the enrollee cash or a cash equivalent as a reward for making
certain choices or exhibiting behaviors associated with improved health. Examples
of cash equivalent rewards include gift cards, gift certificates, diner’s club points,
provision of transportation, and memberships to gyms or other programs.

For technical support to qualify as an in-kind incentive, it must not only include data collection/sharing, but must
also include resources like people or systems/infrastructure (e.g., Electronic Medical Records [EMRs], computers,
phone banks) to support both collection and use of the data.

pg. 80

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year

Appendix F. Glossary
Unless otherwise stated in this document, the definitions in Exhibit 30 are QIS-specific, apply to
key terms, and are defined within the context of the QIS requirements. Some of these terms may
be defined differently in other contexts.
Exhibit 30: Glossary
Term

Definition

Areas Health
Resources Files
(AHRF)

The AHRF are Health Resources and Service Administration (HRSA) databases that
provide a comprehensive set of county, state, and national data. The data offer a broad
range of health resources and socioeconomic indicators that impact demand for health
care.

Baseline data

Baseline data is the initial collection of data which serves as a basis for comparison with
the subsequently acquired data.

Certification

The process by which issuers are evaluated and their health plans are recognized as
meeting the predetermined criteria and standards described in 45 CFR § 156 Subpart
C. 67

Co-insurance

A QHP enrollee’s share of the costs of a covered health care service, calculated as a
percent (e.g., 20%) of the allowed amount for the service. 68

Consensus-based
Entity (CBE)

Organization that is responsible for the endorsement and maintenance of the health
care performance measures that are used throughout the Centers for Medicaid and
Medicare Services (CMS) programs.

Co-payment

A fixed amount a QHP enrollee pays for a covered health care service, usually at the
time of service. The amount can vary by the type of covered health care service. 69

Criteria

Criteria describe the type of information issuers must provide and are the rules that an
Exchange will use to evaluate whether an issuer’s QIS fulfills the QIS requirements.

Element

Identifying and descriptive information that issuers will use to complete the QIS
Implementation Plan and QIS Progress Report. Each element has associated criteria
that describe the type of information issuers must provide.

Exclusive Provider
Organization (EPO)

A type of health insurance product that usually limits coverage to care from providers, or
groups of providers, that have contracts with the health insurance issuer to be part of a
network of participating providers. EPO enrollees will generally not be reimbursed or
receive benefits for out-of-network services; however, some EPOs will provide partial
reimbursement for emergency situations.

Federally-facilitated
Exchanges (FFEs) or
Federally-facilitated
Marketplaces (FFM)

The Exchange models operated by HHS for individual and small group market
coverage.

Health Insurance
Exchange
(Exchange) or Health
Insurance
Marketplace®70
(Marketplace)

A resource in each state where qualified individuals, families, and small businesses can
learn about their health insurance options; compare QHPs based on quality, costs,
benefits, and other important features; choose a QHP; and enroll in coverage. In some
states, the Exchange is operated by the state. In others, it is operated by the federal
government.

Patient Protection and Affordable Care Act. http://housedocs.house.gov/energycommerce/ppacacon.pdf
https://www.healthcare.gov/glossary/co-insurance/
69
https://www.healthcare.gov/glossary/co-payment/
70
Health Insurance Marketplace® is a registered service mark of the U.S. Department of Health & Human Services.
67
68

pg. 81

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Term

Definition

Health Insurance
Oversight System
(HIOS)

A data submission tool that allows CMS to collect data from states and individual and
small group market issuers, which will be aggregated with other data sources and made
public on a consumer-facing website. The initial mechanism for the states and issuers to
submit their data is through the use of the HIOS form.

Health Maintenance
Organization (HMO)

A type of health insurance product that usually limits coverage to care from providers
that work for or contract with the HMO and generally will not cover out-of-network care,
except in an emergency.

Hospital Value-Based
Purchasing program

Hospital Value-Based Purchasing (VBP) is part of the Centers for Medicare & Medicaid
Services’ long-standing effort to link Medicare’s payment system to a value-based
system to improve health care quality, including the quality of care provided in the
inpatient hospital setting.
The program attaches value-based purchasing to the payment system that accounts for
the largest share of Medicare spending, affecting payment for inpatient stays in over
3,500 hospitals across the country.
Participating hospitals are paid for inpatient acute care services based on the quality of
care, not just quantity of the services they provide. Congress authorized Inpatient
Hospital VBP in Section 3001(a) of the Patient Protection and Affordable Care Act. The
program uses the hospital quality data reporting infrastructure developed for the
Hospital Inpatient Quality Reporting (IQR) Program, which was authorized by Section
501(b) of the Medicare Prescription Drug, Improvement, and Modernization Act of
2003. 71

Marketplace Plan
Management System
(MPMS)

MPMS is a web application where users can validate plan data and submit their QHPs
and Stand-Alone Dental Plans (SADPs) to CMS for review and certification.

Medicare Shared
Savings Program

CMS has established a Medicare Shared Savings Program to facilitate coordination and
cooperation among providers to improve the quality of care for Medicare fee-for-service
beneficiaries and reduce unnecessary costs. Eligible providers, hospitals, and suppliers
may participate in the Shared Savings Program by creating or participating in an
Accountable Care Organization (ACO).
The Shared Savings Program is designed to improve beneficiary outcomes and
increase value of care by:
 Promoting accountability for the care of Medicare FFS beneficiaries
 Requiring coordinated care for all services provided under Medicare FFS
 Encouraging investment in infrastructure and redesigned care processes
The Shared Savings Program will reward ACOs that lower their growth in health care
costs while meeting performance standards on quality of care and putting patients first.
Participation in an ACO is purely voluntary. 72

Payment Structure

Provider payments or enrollee benefits used by health plans to improve quality and
reduce costs by incentivizing providers and enrollees toward high-value care, rather
than volume-driven care. 73

Performance
Measure

The quantitative data that issuers will use to measure whether their quality improvement
strategy is meeting their established goals.

Point of Service
(POS)

A type of health insurance product modeled after an HMO, but with an opt-out option. In
this type of product, enrollees may choose to receive services either within the
organization’s health care system (e.g., an in-network practitioner) or outside the
organization’s health care delivery system (e.g., an out-of-network practitioner). The
level of benefits or reimbursement is generally determined by whether the enrollee uses
in-network or out-of-network services.

https://qualitynet.cms.gov/inpatient/hvbp
http://www.cms.gov/Medicare/Medicare-Fee-for-ServicePayment/sharedsavingsprogram/index.html?redirect=/sharedsavingsprogram/
73
https://www.cms.gov/medicare/quality/value-based-programs
71
72

pg. 82

Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Term

Definition

Preferred Provider
Organization (PPO)

A type of health insurance product that usually limits coverage to care from providers, or
groups of providers, who have contracts with the health insurance issuer to be part of a
network of participating providers. PPO enrollees may use providers outside of this
network, but out-of-network services are usually covered at a reduced rate (e.g.,
reduced reimbursement percentages, higher deductibles, higher co-payments).

Premium

The amount that must be paid monthly, quarterly, or yearly for an enrollee’s health
insurance.

Provider

A provider is an organization, institution, or individual that is a supplier of medical
services.

QIS evaluation

The process for assessing and scoring an issuer’s QIS submission to determine
whether the issuer has fulfilled the QIS requirements.

QIS evaluation
threshold

The standard for demonstrating compliance with the QIS requirements, which will be
meeting a predefined number of evaluation criteria and must-pass criteria.

QIS Implementation
Plan form

The QIS Implementation Plan form is a form QHP issuers in the FFE use for annual
reporting to the applicable Exchange. The form comprises three sections: QIS
Submission Type, Background Information, and QIS Implementation Plan. Issuers
complete the QIS Implementation Plan form to describe and report their quality
improvement strategies to the applicable Exchange.

QIS Modification
Summary
Supplement form

The QIS Modification Summary Supplement form is a form QHP issuers in the FFE use
for annual reporting to the applicable Exchange. The form comprises three sections:
QIS Submission Type, Background Information, and QIS Modification Summary.
Issuers use this form if they are reporting changes that warrant modification to an
existing QIS (i.e., changes to topics areas, goals, activities, measures, performance
targets, or product types). This is not a standalone form and must be submitted in
conjunction with the Progress Report form.

QIS Progress Report
form

The QIS Progress Report form is a form QHP issuers in the FFE use for annual
reporting to the applicable Exchange. The form comprises three sections: QIS
Submission Type, Background Information, and QIS Progress Report. Issuers that have
already implemented a QIS complete the QIS Progress Report form annually to
communicate their quality improvement strategies’ progress to the applicable Exchange.

QIS requirements

The statutory requirements for QIS, according to PPACA sections 1311(c)(1)(E) and
1311(g) and accompanying federal regulations, including: (1) implementation of a
quality improvement strategy described as a payment structure that provides increased
reimbursement or other incentives for reducing health and health care disparities and
addressing at least one of the other topic areas listed in section 1311(g), (2) complying
with guidelines established by the Secretary of HHS in consultation with experts in
health care quality and interested parties, and (3) reporting QIS progress to the
applicable Exchange on an annual basis.

QIS scoring
methodology

The criteria used to systematically determine a strategy’s merit, using criteria governed
by a set of standards.

QHP Application and
Certification Process

The process by which issuers apply for QHP certification, and through which the
applicable Exchange reviews applications and makes QHP certification determinations.

QHP Application
Submission and
Review Period (QHP
Application Period)

The specific time frame in which an issuer submits its QIS to the applicable Exchange
for evaluation and review and the Exchange notifies issuers if their QIS submissions
have been approved. The period typically takes place from mid-April to mid-September.

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Quality Improvement Strategy Technical Guidance and User Guide for the 2025 Plan Year
Term

Definition

Qualified Health Plan
(QHP)

A QHP is a health insurance plan that has in effect a certification that it meets the
standards established by the Patient Protection and Affordable Care Act and supporting
regulation, issued or recognized by the applicable Exchange through which such plan is
offered. 74

Qualified Health Plan
issuer (QHP issuer)

A health insurance issuer that offers a QHP in accordance with a certification from an
Exchange, as defined by 45 CFR § 155.20. Each QHP issuer is defined by a separate
federal HIOS Issuer ID. Each QHP issuer is defined by a state geographic unit. 75 An
issuer is considered to be a “QHP issuer” once certification has been completed.

Quality improvement

Documented improvement in defined health care quality indicators. Quality
improvement is process based, data driven, and a continuous process.

Quality improvement
strategy (QIS)

A QIS (as a noun) as described in Section 1311(g) of the Patient Protection and
Affordable Care Act is implemented by an issuer to satisfy the related statutory
certification requirement to participate in Exchanges.

QIS (as a modifier)

The QIS acronym can also be used as a modifier to provide context (e.g., QIS
legislation, QIS implementation).

Quality Rating
System (QRS)

The QRS is a rating system, similar to CMS’ Medicare Stars, designed to inform
consumer and employer selection of QHPs offered through the Exchanges.

State-based
Exchange (SBE)

An Exchange model in which a state operates its own Health Insurance Exchange for
both the individual and small group markets. A state-based Exchange is responsible for
certifying issuers, overseeing issuer compliance with federal Exchange quality
standards as a condition of certification.

State-based
Exchange on the
Federal Platform
(SBE-FP)

An Exchange model in which a state operates its own Health Insurance Exchange SM, for
both the individual and small group markets, but relies on the federal platform to
perform certain eligibility and enrollment functions. An SBE-FP is responsible for
certifying issuers, overseeing issuer compliance with federal Exchange quality
standards as a condition of certification.

States performing
plan management

FFEs where the state performs plan management for QHPs offered through the
Exchange. Consumers in these states apply for and enroll in coverage through the
FFEs.

System for Electronic
Rate Filing and
Forms (SERFF)

SERFF is an electronic filing mechanism that allows for standardized health product
filings, including rate review and QHP submissions. SERFF is affiliated with the National
Association of Insurance Commissioners (NAIC).

Topic areas

The specific areas for quality improvement cited in Section 1311(g) of the Patient
Protection and Affordable Care Act. They include health outcomes, readmissions,
patient safety, wellness and health promotion, and disparities.

Work Plan

A detailed plan developed by an issuer that provides a resolution for any identified
errors with the issuer’s QIS submission. An issuer’s Work Plan is generally submitted to
the Exchange for evaluation following the QHP Application Submission and Review
Period.

Exchange and Insurance Market Standards for 2015 and Beyond Final Rule.
https://www.cms.gov/CCIIO/Resources/Fact-Sheets-and-FAQs/marketstandards-5-16-2014.html
75
Ibid.
74

pg. 84

Quality Improvement Strategy Technical Guidance and User Guide for the 2024 Plan Year

Appendix G. Acronym List
Exhibit 31 includes acronyms used in this document.
Exhibit 31: Acronym List
Acronym

Complete Term or Name

ACO

Accountable Care Organization

AHRF

Area Health Resource File

CBE

Consensus-based Entity

CCIIO

Center for Consumer Information & Insurance Oversight

CMS

Centers for Medicare & Medicaid Services

EPO

Exclusive Provider Organization

FFE

Federally-facilitated Exchange

FFM

Federally-facilitated Marketplace

HHS

U.S. Department of Health and Human Services

HIOS

Health Insurance Oversight System

HMO

Health Maintenance Organization

HRSA

Health Resources and Services Administration

HSA

Health Savings Account

IQR

Inpatient Quality Reporting

MPMS

Marketplace Plan Management System

LAN

Learning & Action Network

MQI

Marketplace Quality Initiatives

MSD

Marketplace Service Desk

NAIC

National Association of Insurance Commissioners

PCA

Post-Certification Assessment

POC

Point of Contact

POS

Point of Service

PPACA

Patient Protection and Affordable Care Act

PPO

Preferred Provider Organization

QHP

Qualified Health Plan

QIS

Quality Improvement Strategy

QRS

Quality Rating System

SADP

Stand-alone Dental Plan

SBE

State-based Exchange

SBE-FP

State-based Exchange on the Federal Platform

SERFF

System for Electronic Rates and Forms Filing

SERVIS

State Exchange Resource Virtual Information System

SHOP

Small Business Health Options Program

SMIPG

State Marketplace and Insurance Programs Group

TIN

Tax Identification Number

pg. 85

File Type	application/pdf
File Title	Quality Improvement Strategy: Technical Guidance and User Guide for the 2025 Plan Year
Subject	QHP issuer, QIS, Health Insurance Exchange, Quality Improvement Strategy
Author	Centers for Medicare & Medicaid Services
File Modified	2024-08-14
File Created	2024-03-27