Anatomy IT Advocates for ASCQR Clients in 2026

September 19, 2025

Anatomy IT (AIT) asks Centers for Medicare and Medicaid Services (CMS) to consider your experience with quality reporting in comments submitted on the 2026 ASC Quality Reporting Program (ASCQR) proposed rule. See our previous blog for a summary of the proposed changes to the ASCQR in 2026.

ASCQR Comments

In this proposed rule, CMS introduced one new measure and proposed the removal of four measures. We summarize the comments included in AIT’s letter to CMS on the 2026 ASCQR proposals below.

Proposed New Measure

Patient Understanding of Key Information Related to Recovery After a Facility-Based Outpatient Procedure or Surgery (Information Transfer PRO-PM)

CMS proposed to make this new measure voluntary for the 2027-2028 performance years and mandatory beginning in 2029. This measure would require ASCs to survey patients on their understanding of provided discharge information after undergoing a surgical or non-surgical procedure at the ASC using a 9-item questionnaire.

AIT expressed our concern that adding another survey to the ASCQR program would increase both the reporting burden for ASCs and the survey fatigue among patients. We recommended that CMS either combine this survey with OAS CAHPS or remove the OAS CAHPS measure.

Proposed Measure Removals

ASC-20: COVID-19 Vaccination Coverage Among Health Care Personnel

We opposed the removal of this measure beginning in 2024, as all data for 2024 has already been submitted.

ASC-22 and ASC-23: Social Drivers of Health Measures

AIT supported the proposed removal of these measures. While the impacts of social drivers of health (SDOH) are significant and crucial for long-term health, ASCs do not provide longitudinal care and are, thus, not an appropriate avenue to address SDOH.

ASC-24: Facility Commitment to Health Equity (FCHE)

Similar to our comments on the SDOH measures, we supported the removal of ASC-24 because, although we strongly believe in the need for health equity, ASCs are not the best setting to address the comprehensive nature of this measure.

Additional Comments

In response to the request for feedback on introducing well-being and nutrition concepts into the ASCQR program, we emphasized that ASCs do not provide longitudinal care and therefore, as with the SDOH and FCHE measures, are not the correct setting for these types of measures.
We generally supported the proposed updates to the Extraordinary Circumstances Exception (ECE) policy, but we opposed the proposal that would reduce the time ASCs have to submit an ECE request to only 30 days from the date of the ECE (currently 90 days).

Next Steps

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Written By: Sarrah Hakim, MHSA