Home Health & Hospice Week

The new Medicare patient satisfaction survey requirement may have been delayed six months, but you'll likely need that extra time to figure out how to navigate the program's obstacles.

In the PPS 2010 update final rule in the Nov. 10 Federal Register, the Centers for Medicare & Medicaid Services pushed back the timetable for the Home Health Consumer Assessment of Healthcare Providers and Systems (CAHPS) measure -- but not by much. Home health agencies will have to conduct a "dry run" of CAHPS data submission in the third quarter of 2010 and start submitting CAHPS data routinely by October of next year.

While the program is "voluntary" for now, HHAs that don't participate will see a 2 percent payment update reduction starting in 2011, CMS says in the rule.

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.

Know Your CAHPS Hot Spots

HHAs will have these major challenges to tackle when they begin the program, experts predict:

• Patient list. "The most challenging part logistically for the agencies will be to gather the lists of eligible patients each month," predicts Chicago-based regulatory consultant Rebecca Friedman Zuber.

One reason is the difficulty of weeding through the rolls to find patients that meet the criteria to be on the survey list (see box, this page, for CAHPS eligibility criteria).

Another is the time constraint. Under the final rule, survey vendors will "initiate the survey for each monthly sample within 3 weeks after the end of the sample month," CMS explains.

"Getting the proper list of names on a timely basis so the vendor can do the survey" will be a major challenge, surmises consultant Betty Gordon with Simione Consultants in Westborough, Mass.

• Survey number. Regardless of their size, HHAs are supposed to target 300 survey completions per year. That will be a tall order for many agencies, experts agree.

In addition to the listed criteria, patients' care must be paid for by Medicare or Medicaid to be included. This was a change from the proposed rule. "Reducing to Medicare and Medicaid only may make it even harder to reach the minimum numbers," worries Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C.

Too long: The length of the survey -- at least 34 questions -- is a reason many patients won't bother to fill it out. "Many agencies will never achieve the required 300 completed interviews because of the length," Friedman Zuber forecasts.

"The survey is so long, it will really be hard to get patients to participate," Adams agrees. The relatively short window of time patients have to fill out the survey is another limiting factor. "All data collection for each monthly sample [must] be completed within 6 weeks (42 days) after data collection began," CMS says in the rule.

Due to these reasons and more, "HHAs serving populations that tend to be poor respondents will be unable to meet this total number, particularly if the agencies themselves are small in size," commenters on the proposed rule told CMS.

Feds' response: CMS stands by its 300-survey number. "HHAs should target 300 completes annually which averages about 25 completes a month," the agency says in the final rule.

However: "We will accept less than 300 survey completes annually if an agency is unable to achieve that number," CMS allows. "Compliance is based on whether the agency did the survey and followed the protocols. It is not based on the number of patients that responded to the survey."

Agencies should survey all CAHPS-eligible patients before throwing in the towel on reaching 300 completes, however, CMS notes. And be careful about accepting a low survey response rate, Gordon cautions. Regulators may see that as a red flag about care quality, inviting more scrutiny of your organization.

• Patient education. HHAs that hope to reach the 300 target and get as much data as possible for their publicly shared outcomes will need to educate patients about the survey. "Patients need to understand the survey's importance," Gordon says.

• Cost. The factor that may keep the most agencies out of the CAHPS game is cost. CMS equires agencies to use a third-party vendor to conduct the surveys. For some agencies, the vendor cost may be higher than the 2 percent update reduction they'd take for not participating (see Eli's HCW, Vol. XVIII, No. 42, p. 323).