Home Health & Hospice Week

With so much on your home health agency's  late, deciding to skip the new patient survey requirement may seem like a good idea. But be sure you've weighed the pros and cons before you go down a road that may put your referrals at stake.

Home health agencies tell Eli they are considering opting out of the Home Health Consumer Assessment of Healthcare Providers and Systems (CAHPS) because the cost of participating will be higher than the 2 percent update reduction they'll be subject to for not submitting CAHPS data.

In comments on the proposed rule, providers told the Centers for Medicare & Medicaid Services they wanted to be able to conduct the survey themselves. But CMS nixed that idea.

"Agencies are not allowed to conduct the survey on their own," CMS confirms in the home health PPS final rule for 2010 published in the Nov. 10 Federal Register. "Since many patients have a continuing relationship with their home health agency, we believe that an independent third party will be better able to solicit an unbiased response," CMS continues.

"Since they receive care in their homes, this population is particularly vulnerable and dependent upon their home health agency caregivers."

Shop smart: HHAs should be able to find an affordable option for the surveys among the 34 vendors CMS has approved so far, the agency maintains. "We recognize that vendors will charge different amounts for the survey, and highly recommend that home health agencies 'shop around' for the best value for their agency," the rule tells providers.

Agencies should research "as many vendors as possible that are listed on the vendor list on http://www.homehealthcahps.org," CMS recommendsin the rule. "We are confident that there are reasonable choices for the HHAs with the current list of vendors."

Despite CMS's assurances, some agencies may find the cost of participating in CAHPS higher than the reduction. In that case, they won't have to join in, CMS says. "Agencies may still choose not to participate in the survey if they believe that the costs of participating will exceed the two percent reduction of the full annual payment update they would otherwise receive," the agency allows.

"It will make sense for some agencies not to do it ... because the financial hit will be less than thecost," observes Chicago-based regulatory consultant

Rebecca Friedman Zuber.

For some HHAs, "costs of doing the surveys may be so high, it would be better to take an overall reduction," agrees clinical consultant Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C.

Look ahead: But don't write off CAHPS forever, Friedman Zuber urges. "I think CMS will either up the hit or the vendors will lower the cost," she predicts.

Or CMS may just make CAHPS mandatory after a test run, experts forecast. Then you'll have to scramble to catch up on the requirement.

Even though CAHPS won't be technically required, providers should think long and hard before opting out of it, counsels consultant Betty Gordon with Simione Consultants in Westborough, Mass.

That's because the CAHPS data will be publicly reported on Home Health Compare. You won't look the same as your other competitors who do have data displayed, which "does not make good business sense," Gordon warns.

Lacking that CAHPS data "will make the non-participant agencies look like they don't care, and that will be bad in a competitive market," Friedman Zuber stresses.

A compromise: HHAs may want to pause and make a call on CAHPS as more details emerge, Adams suggests. If you're considering opting out, "it is time to take a deep breath and see what CMS is planning and then look at options again," she believes.