Medicare Compliance & Reimbursement

You may not have to use the new CAHPS patient satisfaction survey for home health agencies, but chances are you might need to know about it down the road.

The National Quality Forum has endorsed the new 34-question Consumer Assessment of Healthcare Providers and Systems HHA survey and the Office of Management and Budget has concluded its comment period on the new form. Now the Centers for Medicare & Medicaid Services plans to incorporate any final changes and roll out implementation of the voluntary patient satisfaction tool this summer, says contractor RTI on the CAHPS Web site.

Currently, 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 lawmakers and policy advocates 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 (NAHC) in its OMB comment letter. But read on for details about four key problems with the new form that should be ironed out, especially before it becomes mandatory.

"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.

Part of the length problem comes from questions that are redundant, especially from the perspective of nonexpert patients, NAHC maintains.

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 medication 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.

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," the NAHC letter 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.

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," their letter states.