ASC Quality Reporting: Are You on Track for 2026?

January 8, 2026

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 2026 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 60 calendar days* of the date you experienced the circumstance.

*Note that this is a change from last year. Previously, ASCs had 90 days to submit the request, but that was reduced to 60 days in the 2026 Final Rule.

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 2026

  • January 1
    • ASCQR 2026 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, do this as soon as possible.
    • ASCQR 2025 submission window opens for web-based measures reported through the HQR secure portal.
  • January 14
    • Last day for your vendor to submit Q3 data for 2025 to the OAS CAHPS Data Center.
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect November 2025 data.
      • For details on the OAS CAHPS Survey measure, which continues to be mandatory in 2026, check out our previous 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.
  • February 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect December 2025 data.
  • March 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect January 2026 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 2026 Annual Payment Update (APU).

Key Actions for Q1
  • Contract with a CMS-approved survey vendor to report the mandatory OAS CAHPS Survey measure.
  • Register to report OAS CAHPS if you haven’t already (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.
  • Ensure your vendor has submitted 2025 Q3 data to the OAS CAHPS Data Center.
  • Monitor data submission reports through your OAS CAHPS account to ensure there are no issues.
  • Submit a request to CMS for reconsideration of your 2026 APU status, if warranted.

Q2: April – June 2026

  • April 8
    • Last day for your vendor to submit Q4 data for 2025 to the OAS CAHPS Data Center.
  • April 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect February 2026 data.
  • May 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect March 2026 data.
  • May 15
    • Deadline to submit 2025 ASCQR data for web-based measures reported through the HQR secure portal.
  • June 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect April 2026 data.

Key Actions for Q2
  • Provide your OAS CAHPS vendor with patient information files by the agreed upon date each month.
  • Ensure your vendor has submitted 2025 Q4 data to the OAS CAHPS Data Center.
  • Monitor data submission reports through your OAS CAHPS account to ensure there are no issues.
  • Submit 2025 ASCQR data for web-based measures reported through the HQR secure portal.

Q3: July – September 2026

  • July 8
    • Last day for your vendor to submit Q1 data for 2026 to the OAS CAHPS Data Center.
  • Early – Mid July
    • CMS is expected to publish the ASCQR proposed rule for the 2027 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 2026 data.
  • August 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect June 2026 data.
  • September 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect July 2026 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 2026 Q1 data to the OAS CAHPS Data Center.
  • Continue monitoring data submission reports through your OAS CAHPS account to ensure there are no issues.
  • Submit comments on the 2027 ASCQR proposed rule, if you would like CMS to consider your feedback when determining the final rule.

Q4: October – December 2026

  • October 14
    • Last day for your vendor to submit Q2 data for 2026 to the OAS CAHPS Data Center.
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect August 2026 data.
  • November 2
    • CMS is expected to publish the ASCQR final rule for the 2027 performance year by this date at the latest.
  • November 14
    • Last day for your vendor to initiate the OAS CAHPS Survey to collect September 2026 data.
  • Early December
    • Status categories for 2027 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 2026 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 2026 Q2 data to the OAS CAHPS Data Center.
  • Continue monitoring data submission reports through your OAS CAHPS account to ensure there are no issues.
  • Check your 2027 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 the Director of Health Policy at Anatomy IT.

Posted in blog, MIPS