Please see announcement below regarding the CMS Proposed Rule for Calendar Year 2018 for OAS CAHPS. The announcement is followed by additional thoughts from SPH Analytics.
CMS Proposed Ruling for 2018
The Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs Proposed Rule is scheduled to be published in the Federal Register on July 20, 2017. A preview (or “unpublished” version) of the Proposed Rule is available through the link provided here.
In this proposed rule, CMS proposes to delay implementation of the Outpatient and Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS) Survey Based Measures OP-37a-e beginning with the CY 2020 payment determination (2018 data collection) until further action in future CMS-1678-P 477 rulemaking. CMS will continue to analyze the national implementation data and consider any necessary modifications to the survey tool and/or CMS systems.
CMS continues to believe that these measures address an area of care that is not adequately addressed in the current measure set and will be useful to assess aspects of care where the patient is the best or only source of information. These measures will enable objective and meaningful comparisons between hospital outpatient departments and ambulatory surgery centers.
If you have questions, you can contact the OAS CAHPS Survey Coordination Team via e-mail at email@example.com or call 1-866-590-7468.
Reasons for the Proposed Delay
CMS stated there were several factors that led to a proposed delay in the mandatory implementation of OAS CAHPS, namely the overall lack of important operational and implementation data requirements, ensuring that the survey measures appropriately account for patient response rates, both aggregate and by survey administration method, and the additional burden associated with administering the survey in the outpatient setting of care.
CMS did clarify that they will continue to ask ASCs and HOPDs to participate during the voluntary reporting period for the rest of 2017 and for 2018. CMS strongly believes that these measures address an area of care that is not adequately addressed in the current measure set and that the data collected continues to provide objective and meaningful comparisons between hospital outpatient departments.
SPH Analytics Recommendations
SPH echoes the comments from CMS that, in addition to continuing to provide meaningful and useful comparative data, there are a number of beneficial reasons for ASCs and HOPDs to participate during the voluntary reporting period. Voluntary participation provides ASCs and HOPDs the opportunity to:
- Evaluate and begin service recovery and develop action plans related to OAS CAHPS
- Have administration, staff, and physicians learn the program
- Build out the process for data submission
- Get a ‘head start’ on the competition
SPH Analytics’ recommendation to their clients has not changed. CMS has proposed a ‘delay’ in reporting, but not a discontinuation. Although the implementation date may be delayed, ASCs and HOPDs will still need a process for submitting quality measures to CMS that affect reimbursement. It is better to plan ahead, than wait for the mandate and then try to build processes at that time.
Questions? Check out our recent webinar.
SPH Analytics hosted a webinar days after the announcement to address additional questions or concerns individuals may have had regarding the update. The recorded webinar can be viewed below.