2025 Hospital OQR Program Requirements

The Outpatient Quality Reporting (OQR) program is a mandatory reporting program for hospital outpatient departments (HOPD) who submit claims to Medicare and are paid under the OPPS (Outpatient Prospective Payment System). Each year, CMS regulates what information hospitals must submit to complete their OQR program requirements.

As always, we are here to help with a step-by-step guide to everything you need to do to ensure a successful 2025 OQR reporting year. This article explores what's new and what's changed and how your hospital can not only comply with the new requirements but also excel in delivering high-quality patient care.

Take a minute to read through it, then contact us if you have any questions.

A Quick History on OQR

Following CMS’s rollout of the Hospital Inpatient Quality Reporting (IQR) program in 2003, the OQR program was initiated as a mandate of the Tax Relief and Healthcare Act of 2006 and officially launched under the 2009 Outpatient Prospective Payment System (OPPS) Final Rule. Since then, the program has been updated, but in fairly predictable, chart-abstracted measure kind-of ways.

CMS has started to evolve the program gradually by introducing mandatory electronic clinical quality measures (eCQMs) and patient-reported outcome-based performance measures (PRO-PMs) over the next few years. We wouldn’t be surprised to see even more big changes emerge in future rulings.

OQR Rewards & Penalties

One thing that hasn’t changed: what’s at stake. Hospitals receive a 2-percentage point payment reduction if they choose not to participate in the OQR program or fail to meet the program’s requirements. Participation is voluntary for critical access hospitals and hospitals that do not participate in the OPPS.

Also read: How is the OQR penalty calculated?

CMS also publishes hospitals’ measure results on Care Compare as a means of helping consumers choose which hospitals to go to for their care. So, it’s not just money that’s on the line—it’s your brand image and reputation.

Summary of Changes to the OQR Requirements

NEW Mandatory Measures

• HCHE: Hospital Commitment to Health Equity

REMOVED Measures

• OP-8: MRI Lumbar Spine for Low Back Pain
• OP-13: Cardiac Imaging for Preoperative Risk Assessment for Non-Cardiac, Low-Risk Surgery Measure

NEW Voluntary Measures

• Voluntary for reporting year 2025
  • SDOH-01: Screening for Social Drivers of Health
  • SDOH-02: Screen Positive Rate for Social Drivers of Health
  • THA/TKA PRO-PM (started July 1, 2024)
• Voluntary for reporting year 2026
  • Information Transfer PRO-PM (starts Jan. 1, 2026)

2025 OQR Requirements Summary

These mandatory requirements are due quarterly:

1. Submit clinical data for two chart-abstracted measures (OP-18, OP-23)
2. Submit OAS CAHPS survey data (OP-37)
3. Submit COVID-19 web-based measure (OP-38)

These mandatory requirements are due annually:

1. Submit two Hospital Quality Reporting (HQR) web-based measures (OP-22, OP-29)
2. Submit STEMI eCQM (OP-40)

You must also:

1. Regularly review your claims-based data

1. Submit Chart-Abstracted Measures Quarterly

	REQUIREMENT: Hospitals must report four quarters of clinical data for the two mandatory abstraction measures.
	SUBMISSION METHOD: CMS website or designated information system (third-party vendor authorization required)
	DEADLINE: Quarterly

Hospitals with five or fewer quarterly claims

If you have a measure with five or fewer claims (Medicare and non-Medicare combined) in a quarter, you are not required to submit patient-level data for that measure for that quarter. However, you must submit the aggregate population and sample size counts even if the population is zero. Leaving a field blank does not fulfill the requirements.

2. Report OAS CAHPS Data Quarterly

	REQUIREMENT: Hospitals must report five facets of the OAS CAHPS survey measure: About Facilities and Staff, Communication About Procedure, Preparation for Discharge and Recovery, Overall Rating of Facility, and Recommendation of Facility
	SUBMISSION METHOD: CMS website or designated information system (third-party vendor authorization required)
	DEADLINE: Quarterly submission deadlines

3. Report COVID-19 Measure Quarterly

	REQUIREMENT: Hospitals submit the COVID-19 web-based measure
	SUBMISSION METHOD: National Healthcare Safety Network (NHSN) Portal
	DEADLINE: Quarterly Submission Deadlines

4. Submit HQR Web-Based Measures Annually

	REQUIREMENT: Hospitals submit the Left Without Being Seen (OP-22) and Colonoscopy Follow-Up (OP-29) measures. The third measure, Cataracts Visual Function (OP-31) is voluntary.
	SUBMISSION METHOD: CMS website or designated information system (third-party vendor authorization required)
	DEADLINE: May 15, 2026

5. Report eCQMs Annually

2025 Updates: This year, you must submit two self-selected quarters of data for STEMI eCQM. You will be required to submit one additional quarter each subsequent year, culminating in all four quarters of data being required in 2027. Be sure to read our top tips for succeeding with this measure if you haven’t already!

The Outpatient ExRad eCQM is available to submit voluntarily for the first time this year. In 2027, you must submit 2 self-selected quarters of data for this measure and then a full year of data in 2028. Read our how-to guide for setting up the measure to get a head start.

	REQUIREMENT: Hospitals submit two self-selected quarters of data for the STEMI eCQM
	SUBMISSION METHOD: CMS website or designated information system (third-party vendor authorization required)
	DEADLINE: May 15, 2026

Additional eCQM Requirements: Hospitals must use the most recent version of the eCQM specifications. All data must be submitted using the QRDA I (Quality Reporting Document Architecture) file format. File submission must include one QRDA file per patient that contains all episodes of care and the relevant measure data.

If a hospital has five or fewer outpatient STEMI discharges per quarter or 20 or fewer outpatient STEMI discharges per year (Medicare and non-Medicare combined), as defined by the eCQM’s denominator population, it could be exempt from reporting on this eCQM. Case threshold exemptions should be entered on the Denominator Declaration screen within the HQR System during the submission period.

Note: Hospitals are no longer required to use Alara Imaging for the ExRad eCQM.

6. Report Structural Measures Annually

	REQUIREMENT: Hospitals must submit one Structural measure.
	SUBMISSION METHOD: Hospital Quality Reporting (HQR) System
	DEADLINE: May 15, 2026

7. Voluntarily Submit Two Process Measures Annually

	REQUIREMENT: Hospitals must submit one Structural measure.
	SUBMISSION METHOD: Hospital Quality Reporting (HQR) System
	DEADLINE: May 15, 2026

Other Considerations

Hospitals may use a self-selected screening tool to implement these measures. CMS points to AHC Health-Related Social Needs Screening Tool, which outlines the questions you could put on a form.

CMS also acknowledges that this data could come from multiple sources: administrative claims data, electronic clinical data, standardized patient assessments, or patient-reported data and surveys. For more guidance, be sure to read our Intro to CMS’s SDOH Measures guide.

8. Voluntarily Submit PRO-PMs

2025 Update: Hospitals may elect to report the Outpatient THA/TKA measure voluntarily for the first time this year.

CMS introduced a new PRO-PM to the OQR program, the Information Transfer PRO-PM. Unfortunately, this measure does not have the same encounter or submission dates as the THA/TKA PRO-PM. Start looking into this measure now to allow for voluntary reporting in 2026.

9. Review Your Claims-Based Data

	REQUIREMENT: Hospitals are evaluated for their performance on claims-based measures in 2 measure sets: imaging efficiency measures and outcome measures.
	SUBMISSION METHOD: No additional submission is required
	DEADLINE: No submission deadline

Claims-Based Imaging Efficiency Measures

Claims-Based Outcome Measures

10. Submit Population and Sample Size Data

	REQUIREMENT: Hospitals must submit population and sampling numbers for the two chart-abstracted measures and the HQR web-based measure. Hospitals must also submit numbers for the voluntary Cataracts HQR web-based measure if participating in the measure.
	SUBMISSION METHOD: CMS website or designated information system (third-party vendor authorization required)
	DEADLINE: Quarterly Submission Deadlines (Abstracted measures) Annual Submission Deadlines (Web-based measures)

Note: Hospitals are not required to sample their data if they elect to include all eligible cases. For example, a hospital has 100 cases for the quarter and must select a sample of 80 cases. The hospital may choose to use all 100 cases given the minimal benefit sampling would offer. Each measure has its own sampling requirements that must be met. CMS has outlined the latest requirements here.

The Denominator for OP-22 is the Emergency Department Volume (EDV), calculated by CMS based on your Medicare claims

11. Plan Ahead for the 2026 OQR Reporting Year

As we mentioned at the top, this year is the start of a major evolution in the OQR program. Per the final rule, CMS is bringing new measures and new measure types to the program in the next three years:

• NEW: ExRad eCQM – Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults (Hospital-Level, Outpatient) Electronic Clinical Quality Measure

• NEW: THA/TKA PRO-PM - Risk Standardized Patient-Reported Outcome-Based Performance Measure (PRO-PM) Following Elective Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) in the HOPD Setting
• NEW: Information Transfer PRO-PM - Patient Understanding of Key Information Related to Recovery After a Facility-Based Outpatient Procedure or Surgery, Patient Reported Outcome-Based Performance Measure

We recommend using this year to strategize how your hospital will address each of these measures, so that you can take full advantage of the voluntary reporting periods when they start. The more voluntary reporting you do, the better your mandatory reporting rates will be. 

Get 1:1 Help with Your OQR Requirements

If you’re still feeling overwhelmed by your OQR requirements, Medisolv is just one call away. We work with leading hospitals and health systems across the country just like yours to organize, update, simplify, and streamline their OQR program reporting and processes. Plus, our Medisolv Quality Reporting and Management software platform makes it dramatically easier to meet all your regulatory requirements, maximize your reimbursements, and improve patient care every day.

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