CMS finalizes decision to require OAS CAHPS starting in January 2018

OAS CAHPS survey

In its Final Rule, which was published on November 14, 2016, the Centers for Medicare and Medicaid Services (CMS) announced that it will require hospitals and ambulatory surgery centers to administer the Outpatient Ambulatory Surgery (OAS) CAHPS survey starting with patients treated in January 2018. Calendar year 2018 will be the first data collection period to impact reimbursements paid for FFY 2020. The program will begin as a “pay for reporting” program, meaning that hospitals and ambulatory surgery centers paid by CMS through the Outpatient Prospective Payment System (OPPS) will see a 2% reduction in their reimbursements if they don’t comply with the new quality reporting measure.

CMS is implementing the OAS CAHPS survey in much the same way it rolled out the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) survey, beginning with a voluntary trial period followed by a pay for reporting period. PRC expects that a pay for performance/value-based purchasing period is in the future, as well, although CMS has not yet shared any specifics. One important difference between OAS CAHPS and HCAHPS is that small hospitals and small ambulatory surgery centers may request an exemption from the OAS CAHPS requirement if they see fewer than 60 survey-eligible patients for the calendar year period prior to the data collection period. The size exemption application for January through December 2018 data collection will be due May 15, 2018, but that form is not yet available. Critical access hospital outpatient departments and ambulatory surgery centers that don’t qualify for the Ambulatory Surgical Center Quality Reporting program (ASCQR) are not required to participate, but are welcome to submit voluntarily.

Hospitals were allowed to begin conducting the OAS CAHPS survey voluntarily with January 2016 patients. As of November 14, 2016, PRC is administering the survey for 68 facilities. CMS and PRC have both learned a great deal through their work with these early volunteers. CMS will be hosting its annual Vendor Update Training for CMS-approved OAS CAHPS vendors this week, and we expect to learn about several clarifications to the protocols and guidelines. Be sure to register for our post-training webcast on December 7.

If your organization would like to learn more about what you’ll need to do to convert your existing measurement or start a new measurement program for your ambulatory surgery patients, please contact your PRC Project Manager.