New patient satisfaction survey has four big flaws, reps point out. The For now, it's up to agencies whether they want to voluntarily collect the survey data through a vendor. But if they do, their scores after four quarters of collection will go onto the Home Health Compare Web site. Pretty soon, the survey may not be optional,industry veterans predict. That's because law- and policymakers may be eager to use CAHPS-collected measures as part of a pay for performance (P4P) payment structure. Having a standardized patient satisfaction tool that allows HHAs to compare themselves is a good idea, says the National Association for Home Care & Hospice in its OMB comment letter. But there are four key problems with the new form that should be ironed out, especially before it becomes mandatory: • Length. "We remain concerned about the practicality of an instrument of this size," notes Bob Wardwell with the Visiting Nurse Associations of America, who is retiring from VNAA this summer.CMS cut the questionnaire length from 36 to 34 questions as part of the NQF endorsement process, but that still leaves a lengthy instrument. "Home health patients, most of whom are elderly and frail, may avoid participating in HH CAHPS surveys due to its length," NAHC worries in its comment letter. Both the number of questions and "wordiness of some individual questions" are problems.NAHC urges CMS to streamline the tool. • Repetitive questions. Part of the length problem comes from questions that are redundant, especially to non-expert patients, NAHC maintains. For example: "From a clinical practice perspective,there are important differences between the [seven] medication questions posed," NAHC notes."However, patients may find them redundant and confusing since the wording of these questions is very similar." Some of the questions may not be "really understandable to all patients," fears Wardwell, a former top CMS official. NAHC urges CMS to cut five of the med questions and consolidate some of the queries into one new question. Similarly, three questions about which disciplines patients saw could be combined into one concise question, the trade group suggests. • Respondents. Findings may be suspect due to "the issue of who actually is responding when patients are so debilitated," Wardwell tells Eli. "The survey appears to require either a patient or family member who is proficient in reading," NAHC adds. "It is not clear from the background information provided whether the survey was tested to ensure that patients with a low level of education would be able to read, understand, and comprehend the fine nuances of the questions." CMS plans to explore risk adjustment based on patient characteristics as agencies start collecting and reporting data, it says. • What's measured. The risk of a satisfaction survey is that respondents may favor less efficient but nicer staffers over those who are more effective but not as "sweet," Wardwell notes. To guard against this risk, CMS should add a question about a patient's improved functional status, NAHC suggests. "Since publicly reported outcome measures for home health agencies focus on whether the care provided has resulted in improved functional status, addition of a patient perception question about this should be considered." On May 15 CMS issued a new Protocols and Guidelines Manual on the CAHPS Web site. There are also English and Spanish language forms available. HHAs can add their own questions to the CAHPS survey, but they must follow the 34 core questions, CMS instructs. There are also some suggested supplemental questions HHAs may want to use on the CAHPS site. RTI will conduct a "mode experiment,"where it tests the effect of three data collection modes (phone, mail, or a combination), later this year. "If the mode experiment suggests that the method of data collection has a significant impact on responses, CMS will use the results of the experiment to make appropriate adjustments in the reporting of the survey results," the agency pledges. HHAs shouldn't expect any big changes to the CAHPS questionnaire itself, Wardwell predicts."I think what we see is about what we are going to get," he observes. Note: The CAHPS Web site is at https://homehealthcahps.org. To see the new manual, choose the "General Information" tab and click on "What's New."