On December 17, 2014, the Centers for Medicare and Medicaid Services (CMS) published on its website a Frequently Asked Questions (FAQs) on its Quality Rating System (QRS) and Qualified Health Plan (QHP) Enrollee Experience Survey for QHPs on the insurance exchanges. Section 1311(c)(3) of the Affordable Care Act (ACA) requires CMS to develop a system that rates QHPs based on quality and price. All QHP issuers that offered a category of coverage through any exchange during the prior benefit year and meet minimum enrollment criteria are subject to QRS requirements. To comply, QHP issuers must collect and submit third-party validated QRS measure data, which CMS uses to calculate QHP scores and ratings. Additionally, CMS developed the QHP Enrollee Survey to gather consumer experience data for the QRS. While exchanges are not required to publicly display QRS ratings for 2015 because it is the beta testing period, CMS will require public display of QRS rating information beginning in fall of 2016 for the 2017 open enrollment. The FAQs explained that QRS data will be released via a numeric score and a star rating for each applicable product, along with a single global score and rating. CMS also explained that multiple exchange products may not be combined for the QRS reporting, and that QRS data is provided at the product level.

The FAQ also addresses whether issuers may include enrollees that are in non-exchange plans in their QRS data submissions. While generally, only exchange members should be included in QRS submissions, CMS recognized and accepted that in the 2015 beta testing, certain data submissions did not consistently separate exchange and non-exchange members due to inconsistent use of an identifier in Health Insurance Oversight System, the master federal database, and consequently, some QHP issuers likely included a mix of exchange and non-exchange enrollees in their QRS data.

In addition, the FAQs clarified that QHP issuers must comply with the QRS and QHP Enrollee Survey requirements as well as any other quality measures imposed by the respective states where the issuers offer QHPs. The FAQs are available here.