In its Proposed Rule released on Wednesday, July 6, 2016, the Centers for Medicare and Medicaid Services (CMS) announced its intention to require administration of the Outpatient/Ambulatory Surgery (OAS) CAHPS survey as of January 2018 patients. Calendar year 2018 will be the first data collection period to impact reimbursements paid for FFY2020. The program will begin as a “pay for reporting” program, meaning that hospitals and ambulatory surgery centers that are paid by CMS under the Outpatient Prospective Payment System (OPPS) will see a 2% reduction in their reimbursements for non-compliance with this new quality reporting measure.
This implementation is very similar to how the HCAHPS program began, with a voluntary period followed by a pay for reporting period. We expect that a pay for performance/value-based purchasing period is in the future as well, although no specifics have been shared by CMS. One important difference for OAS CAHPS is that small hospitals and small ambulatory surgery centers may request an exemption from the program if they see fewer than 60 survey-eligible patients for the calendar year prior to the data collection period. For the first CY2018 period, small hospitals and ambulatory surgery centers will have until May 15, 2018, to submit their exemption request; the online form will be available in early 2018.
As you may be aware, it was this same Federal Register notice where CMS proposed suspending the Pain Management scoring as part of the Hospital Value-Based Purchasing program, due to concerns that the financial implications of those results may be contributing to the opioid epidemic. CMS addressed this concern relative to the OAS CAHPS survey as well. CMS plans to include the existing Pain Management dimension in its OAS CAHPS survey, distinguishing that in the OAS CAHPS survey, the questions focus on pain management that patients may address themselves after they are discharged.
Hospitals could begin voluntarily administering the OAS CAHPS survey with January 2016 patients, and PRC has worked with several clients already to implement this new survey. CMS and PRC have both learned a great deal through our work with these early volunteers. CMS will be hosting their annual Vendor Update Training for CMS-approved OAS CAHPS vendors in October, and we expect to learn about several clarifications to the protocols and guidelines.
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 Project Manager or email [email protected].