Home Health & Hospice Week

Most home health agencies are consumed with OASIS C beginning next month, but that shouldn't cause the new Home Health Consumer Assessment of Healthcare Providers and Systems (CAHPS) requirement to fall off your priority list.

Participation in CAHPS is voluntary, according to the Centers for Medicare & Medicaid Services' prospective payment system final rule for 2010, published in the Nov. 10 Federal Register.

Watch out: However, agencies that don't submit CAHPS data will be subject to a 2 percent reduction in PPS payment updates starting in 2012, CMS spells out in the rule.

Don't let the 2012 date fool you, industry experts warn. The rule actually requires HHAs to do a "dry run" of CAHPS data submission in the third quarter of 2010 and start submitting CAHPS data routinely by October of next year.

Providers "will need to get serious about it by early in the second quarter of 2010," advises Chicago-based regulatory consultant Rebecca Friedman Zuber.

Agencies should go ahead and select a CAHPS vendor and move forward with implementation right away, advises consultant Betty Gordon with Simione Consultants in Westborough, Mass.

HHAs that are already conducting patient satisfaction surveys may find their current vendor already on the list of approved CAHPS vendors, Gordon notes. CMS has approved 34 vendors for the survey tool so far, the agency says in the rule.

Resource: For a list of vendors and other CAHPS information, go online to www.homehealthcahps.org.

CMS is allowing agencies that want to pilot the program to conduct the CAHPS surveys now, the agency notes.

HHAs that participate in the CAHPS program must contract with a third party vendor to conduct patient satisfaction surveys that include 34 core required questions and nine optional ones. Agencies may also add their own unique questions to the tool, CMS allows.

The tool aims to "produce comparable data on patients' perspectives of care that allow objective and meaningful comparisons between home health agencies," CMS explains.

Exemptions: Agencies must target completion of 300 surveys regardless of how many patients they serve. However, agencies that serve fewer than 60 survey-eligible patients annually are exempt from the new measure, CMS notes in the rule. And new HHAs won't have to submit CAHPS data for their first year.

The results should be statistically significant no matter how big a ratio the 300 surveys represents, CMS maintains. "Surveying a sample of 300 will produce the same level of precision whether the sample is 10 percent, 1 percent or even 0.01 percent of the total population," according to the rule.

CMS made three big changes to the CAHPS program from its proposed version. It pushed the implementation date back six months, restricted the eligible patient pool to those enrolled in Medicare and Medicaid, and allowed the use of V codes for patients if ICD-9 codes for them are not available (see Eli's HCW, Vol. XVIII, No. 39, p. 299).

The feds also assured HHAs that the survey results will account for patient mix. "Patient-mix adjustments are made when certain patient characteristics that are beyond home health agencies' control impact how a patient responds to the survey,"

CMS explains in the rule. "The patient-mix characteristics that have been identified for possible inclusion cover variables such as overall health status, diagnosis information, age, education, managed care indicator, whether the patient lives alone, and insurance coverage."