Medicare HEDIS, HOS, and CAHPS Reporting Requirements 2025-2026
Relevant to: State Medicare-Medicaid Plan Handbooks, Utilization Management, Audit Protocol, Enrollment and Payment Systems, PACE
Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.
Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.
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Introduction
The Centers for Medicare & Medicaid Services (CMS) released a critical memo detailing the reporting requirements for the Healthcare Effectiveness Data and Information Set (HEDIS®) Measurement Year 2025. This document outlines the obligations for Medicare Advantage Organizations and other specified health plans to submit data by June 15, 2026, also covering the Health Outcomes Survey (HOS) and HOS-M for frailty considerations. Additionally, the memo provides insights into the Comprehensive Care or SNP and CAHPS® Measures for 2026, aiding plans in aligning with compliance criteria.
Key Dates and Deadlines
- Submission of HEDIS MY 2025 summary-level data by June 15, 2026
- Deadline for HEDIS MY 2025 Patient-Level Detail data submission by June 15, 2026
- Correspondence regarding HOS participation by March 30, 2026
- Notification regarding HOS-M participation by March 2, 2026
- Optional HEDIS PLD data submission dry run in April 2026
PACE Compliance
The memorandum includes important considerations for PACE (Programs of All-Inclusive Care for the Elderly) compliance. While PACE plans are not required to report HEDIS, HOS, or CAHPS measures similar to other MAOs, the HOS-M survey is mandated for PACE organizations with contracts in effect on or before January 1, 2025. These organizations must have a minimum enrollment of 30 members as of February 2026.
Health plan organizations providing services under PACE must ensure compliance with HOS-M survey requirements. This survey assesses the physical and mental health functioning of beneficiaries enrolled in PACE.
To comply, eligible PACE organizations should:
1. Ensure contract effectivity by January 1, 2025.
2. Verify enrollment of at least 30 members in February 2026.
3. Administer HOS-M surveys in 2026 using an approved survey vendor.
4. Receive further correspondence from NCQA regarding HOS-M participation by March 2, 2026.
These requirements are essential for maintaining quality and compliance within PACE programs and ensuring advantageous participation in CMS programs.
Required Actions
1. Ensure all HEDIS MY 2025 summary-level data is submitted to NCQA by 9:00 p.m. Eastern Time on June 15, 2026, with no late submissions allowed.
All organizations new to HEDIS should familiarize themselves with the submission requirements as soon as possible.
2. Submit HEDIS Patient-Level Detail (PLD) data files to CMS’s HEDIS PLD contractor by the same deadline, with exemptions for MMPs terminating as of December 31, 2025.
3. Contract with an approved HOS or HOS-M survey vendor for 2026 HOS and HOS-M survey administration and notify NCQA of your choice.
Ensure that the vendor choice is aligned with your organization’s compliance requirements.
FAQs
- What are the reporting requirements for HEDIS Measurement Year 2025?
- How do healthcare organizations submit HEDIS data?
- What is the CAHPS survey and who is required to participate in 2026?
- What is the Medicare Health Outcomes Survey (HOS)?
- What changes have been made for SNPs in the MY 2025 HEDIS reporting?
