ASC Quality Reporting: Are You on Track for 2025?

February 4, 2025

In this blog, we highlight important ASCQR dates and action items. You can use the key action checklists provided throughout the blog to stay on track during the 2025 performance year.

If you are unable to submit any required data for the ASCQR program due to an extraordinary circumstance, you may request an exception by completing the Extraordinary Circumstances Exception form and submitting it per the instructions on the form. You must submit this form, along with any supporting documentation, within 90 days of the date you experienced the circumstance.

If you qualify for an exception through a blanket waiver by CMS (e.g., you are in the designated area for a widespread natural disaster), you are not required to submit the form.

Q1: January – March 2025

  • January 1
    • ASCQR 2025 performance year begins.
      • Anatomy IT clients: If you have any workflow changes affecting ASCQR measures, be sure to follow up with your ASCQR Expert.
      • If you haven’t already contracted with a CMS-approved survey vendor to report the OAS CAHPS measure in 2025, do this as soon as possible.
    • ASCQR 2024 submission window opens for web-based measures reported through the HQR secure portal.
  • February 18
    • Deadline to submit 2024 Q3 data for ASC-20: COVID-19 Vaccination Coverage Among Healthcare Personnel.
  • February 21
    • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect January data.
      • For details on the OAS CAHPS Survey measure, which is mandatory in 2025, check out our blog.
      • Anatomy IT clients: We may be able to help you monitor data submission progress throughout the year on the OAS CAHPS Survey measure. Reach out to your ASCQR Expert for more information.
    • March 14
      • Last day for your vendor to initiate the OAS CAHPS Survey to collect January data.
    • March 17
      • Last day to submit a request for reconsideration to CMS if they determined that you did not meet the ASCQR requirements for the 2025 Annual Payment Update (APU).
      • March 21
        • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect February data.

Key Actions for Q1
  • Contract with a CMS-approved survey vendor to report the mandatory OAS CAHPS Survey measure.
  • Register to report OAS CAHPS (instructions are included in our blog).
  • Provide your vendor with anything they need from you to administer the OAS CAHPS Survey, such as monthly patient information files.
  • Work with your vendor to establish the dates that they will administer the survey and submit your data to the OAS CAHPS Data Center.
  • Submit 2024 Q3 data for ASC-20: COVID-19 Vaccination Coverage Among Healthcare Personnel.
  • Submit a request to CMS for reconsideration of your 2025 APU status, if warranted.

Q2: April – June 2025

  • April 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect February data.
  • April 21
    • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect March data.
  • May 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect March data.
  • May 15
    • Deadline to submit 2024 ASCQR data for web-based measures reported through the HQR secure portal.
    • Deadline to submit 2024 Q4 data for ASC-20: COVID-19 Vaccination Coverage Among Healthcare Personnel.
  • May 21
    • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect April data.
  • June 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect April data.
  • June 21
    • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect May data.

Key Actions for Q2
  • Provide your OAS CAHPS vendor with patient information files by the agreed upon date each month.
  • If your vendor has started submitting data to the OAS CAHPS Data Center, monitor data submission reports through your OAS CAHPS account to ensure there are no issues.
  • Submit 2024 ASCQR data for web-based measures reported through the HQR secure portal.
  • Submit 2024 Q4 data for ASC-20: COVID-19 Vaccination Coverage Among Healthcare Personnel.

Q3: July – September 2025

  • July 9
    • Last day for your vendor to submit Q1 data to the OAS CAHPS Data Center.
  • Early – Mid July
    • CMS is expected to publish the ASCQR proposed rule for the 2026 performance year. Comment period begins once the rule is posted.
      • We will post a blog about the key proposals. If there are any proposals you find particularly good or bad, please submit comments to CMS before the deadline (60 days after the proposed rule is published).
      • The Anatomy IT Health Policy team will also be submitting comments on the proposed rule. We have seen CMS make program changes based on our comments on previous rules – so rest assured that your voice matters, and CMS takes comments into account when determining the final rule.
    • July 14
      • Last day for your vendor to initiate the OAS CAHPS Survey to collect May data.
    • July 21
      • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect June data.
    • August 14
      • Last day for your vendor to initiate the OAS CAHPS Survey to collect June data.
    • August 15
      • Deadline to submit 2025 Q1 data for ASC-20: COVID-19 Vaccination Coverage Among Healthcare Personnel.*
        • *This date has not been officially posted on the QualityNet website; it is projected based on previous deadlines.
      • August 21
        • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect July data.
      • September 14
        • Last day for your vendor to initiate the OAS CAHPS Survey to collect July data.
      • September 21
        • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect August data.

Key Actions for Q3
  • Provide your OAS CAHPS vendor with patient information files by the agreed upon date each month.
  • Follow up with your vendor to ensure they submitted your Q1 data to the OAS CAHPS Data Center, and continue monitoring data submission reports through your OAS CAHPS account to ensure there are no issues.
  • Submit 2025 Q1 data for ASC-20: COVID-19 Vaccination Coverage Among Healthcare Personnel.
  • Submit comments on the 2026 ASCQR proposed rule, if you would like CMS to consider your feedback when determining the final rule.

Q4: October – December 2025

  • October 8
    • Last day for your vendor to submit Q2 data to the OAS CAHPS Data Center.
  • October 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect August data.
  • October 21
    • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect September data.
  • November 3
    • CMS is expected to publish the ASCQR final rule for the 2026 performance year by this date at the latest.
  • November 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect September data.
  • November 17
    • Deadline to submit 2025 Q2 data for ASC-20: COVID-19 Vaccination Coverage Among Healthcare Personnel.*
      • *This date has not been officially posted on the QualityNet website; it is projected based on previous deadlines.
    • November 21
      • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect October data.
    • Early December
      • Status categories for 2026 Annual Payment Update (APU) determinations are expected to be posted on the QualityNet website.
    • December 14
      • Last day for your vendor to initiate the OAS CAHPS Survey to collect October data.
    • Mid – Late December
      • Anatomy IT clients: A Jumpstart email will be sent to you regarding preparation for 2026 ASCQR.
    • December 21
      • Recommended date for your vendor to initiate the OAS CAHPS Survey to collect November data.
    • December 31

Key Actions for Q4
  • Provide your OAS CAHPS vendor with patient information files by the agreed upon date each month.
  • Follow up with your vendor to ensure they submitted your Q2 data to the OAS CAHPS Data Center, and continue monitoring data submission reports through your OAS CAHPS account to ensure there are no issues.
  • Submit 2025 Q2 data for ASC-20: COVID-19 Vaccination Coverage Among Healthcare Personnel.
  • Check your 2026 APU status.
  • Submit a Participation Exemption Request for the OAS CAHPS Survey, if warranted.

Next Steps

  • Share this information with your colleagues.
  • Subscribe to our blog to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
  • If you are an Anatomy IT client, contact your ASCQR Expert if you have any questions.
  • If you are not an Anatomy IT client, contact us to learn more about our ASCQR and MIPS Success Plans and to reap the rewards of our combined decades of experience.

If you have any questions on this, let us know!

Sarrah Hakim, MHSAWritten By: Sarrah Hakim, MHSA

About the Author: Sarrah is a Manager of Health Policy at Anatomy IT.

Posted in MIPS, blog