ASCQR: What You Have to Report, and When

This is the set for the CY 2026 reporting period, which drives the CY 2028 payment determination. The CY 2025 reporting period, driving CY 2027 payment, uses the same list.

ASC-15a through ASC-15e, the OAS CAHPS survey-based measures: about facilities and staff, communication about the procedure, preparation for discharge and recovery, overall rating of the facility, and recommendation of the facility.

These are mandatory. The first required reporting period was CY 2025, driving the CY 2027 payment determination. You cannot self-administer — 42 CFR 416.310 requires the center to use an approved OAS CAHPS vendor to administer and submit the data.

Claims-based does not mean consequence-free. To be counted, claims must be paid by the Medicare Administrative Contractor by 30 April of the following year, so a chronic billing backlog can distort what CMS calculates about you.

ASC-21, the facility-level total hip and total knee arthroplasty patient-reported outcome-based performance measure. Voluntary for the CY 2025, CY 2026 and CY 2027 reporting periods, then mandatory beginning with the CY 2028 reporting period and the CY 2031 payment determination.

If your center does joints, this is the one to start early on. It requires paired pre-procedure and post-procedure patient-reported data with long collection windows, and building that workflow is not a thing you can do in the last quarter before it becomes mandatory.

The CY 2026 OPPS and ASC final rule — CMS-1834-FC, 90 FR 53448, published 25 November 2025 — removed four measures. Three of them had been added only the year before and never became mandatory.

CMS also declined to adopt the proposed Information Transfer patient-reported outcome measure, stating it was not finalizing it at this time.

Under 42 CFR 416.310, web-based data are submitted between 1 January and 15 May of the year before the payment determination year, and any deadline falling on a weekend or legal holiday moves to the next business day.

A center that does not meet ASCQR requirements receives a 2.0 percentage point reduction to its Medicare annual payment update under the ASC fee schedule. It is taken off the update factor, which makes the practical effect depend on how large the update is that year:

• CY 2026: the update factor is 2.6 percent — a 3.3 percent market basket increase less a 0.7 percentage point productivity adjustment. A non-compliant center receives 0.6 percent.
• CY 2027: the proposed update factor is 2.4 percent, which would leave a non-compliant center at 0.4 percent if finalized as proposed.

Voluntary withdrawal triggers the same penalty and keeps triggering it. Under 42 CFR 416.305(b), a center may withdraw up to and including 31 August of the year preceding a payment determination, but it then incurs the 2.0 percentage point reduction for that year and any subsequent payment determinations until it rejoins by submitting data again.

Under 42 CFR 416.330, a reconsideration request must reach CMS by no later than the first business day on or after 17 March of the affected payment year. The request must include the center’s CCN and associated NPIs, the center’s name, the reasons CMS identified for non-compliance, the specific basis on which the center believes it met the requirements, contact information for designated personnel, and copies of the materials demonstrating compliance including relevant claim documentation. CMS expects to complete review within 90 days of the submission deadline.

There is no appeal beyond it. The regulation states there is no appeal of any final ASCQR payment determination.

CMS may grant an exception where circumstances beyond the center’s control prevent reporting. The request must be submitted within 60 calendar days of the date the extraordinary circumstance occurred. The CY 2026 final rule codified CMS’s discretion to grant an extension in response to such a request rather than only a full exception.

• Low volume. Under 42 CFR 416.305(c), a center with fewer than 240 Medicare claims — primary and secondary payer combined — in an annual reporting period is not required to participate in the subsequent annual reporting period. Worth confirming your own numbers against the current CMS reporting guide, because CMS’s own guides have described the look-back year inconsistently between editions.
• Newly opened centers. A center must have been designated as open in the CMS certification system for at least four months before data collection begins for a payment determination in order to be subject to the requirements.
• Indian Health Service hospital outpatient departments billing under the ASC payment system are not considered ASCs for ASCQR purposes.

1. Register for a HARP account — the HCQIS Access Roles and Profile account used to reach the Hospital Quality Reporting system.
2. Request HQR access: log in with the HARP credentials, go to My Profile, and create an access request.
3. Designate a Security Official. Each facility with a unique NPI needs one. CMS strongly recommends designating at least two — a primary and a backup — and advises establishing the account and role four to six weeks before a submission deadline rather than in the week of it.
4. Keep the account active by logging in at least every 60 days. Dormant accounts lock, and they lock at the worst possible time.
5. Contract with a CMS-approved OAS CAHPS survey vendor. This is not optional and cannot be done in-house.

NHSN enrollment is no longer part of this list for ASCQR purposes, though it may still be required by your state or your accreditor.