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REGULATORY REVIEW


Survey Cohort The OAS CAHPS Survey is adminis- tered to all eligible patients, or a ran- dom sample of all eligible patients, regardless of insurance or method of payment. For purposes of each survey- based measure captured in the OAS CAHPS Survey, an “eligible patient” is a patient 18 years or older who: ■


had an outpatient surgery or proce- dure in an ASC;


■ does not reside in a nursing home; ■


■ is not identified as a prisoner; and ■


was not discharged to hospice care following their surgery;


did not request that ASCs not release their name and contact information to anyone other than ASC personnel. In addition, a patient whose address is not a US domestic address, cannot be surveyed because of state regula- tions, and obviously, patients who are deceased are ineligible.


Sampling Requirement ASCs must survey a random sample of eligible patients monthly and collect at least 300 completed surveys over a 12-month reporting period. Your ven- dor should guide you through the sam- pling process. Smaller ASCs that do not think they will be able to collect 300 completed surveys over a 12-month reporting period but are above the low- volume threshold would be required to survey all eligible patients (that is, no sampling). As a reminder, for all mea- sures in the ASCQR Program, facil- ities are exempt from participation if they bill fewer than 240 Medicare pri- mary and secondary claims in a year.


ASCQR Measures Based Off OAS CAHPS


CMS finalized five survey-based mea- sures derived from the OAS CAHPS survey as part of the reporting require- ments for Medicare’s ASC Quality Reporting Program. Data collection for these new measures begins in cal- endar year (CY) 2018 and will impact


The OAS CAHPS Survey is administered to all eligible patients—or a random sample of all eligible patients, regardless of insurance or method of payment.”


—Kara Newbury, ASCA


payment determinations in CY 2020. Three of the five measures are OAS CAHPS composite survey-based mea- sures consisting of six or more ques- tions. ASC rates on each composite OAS CAHPS Survey-based measure would be calculated by determining the proportion of “top-box” responses (that is, counting only the “Yes” or “Yes Definitely” answers) for each question within the composite and averaging these proportions over all questions in the composite measure. These mea- sures are: ■


ASC-15a: OAS CAHPS—About Facilities and Staff;


■ ■


ASC-15b: OAS CAHPS—Commu- nication About Procedure; and


ASC-15c: OAS CAHPS—Prepara- tion for Discharge and Recovery. The two other measures are global


survey-based measures made up of a single question each and ask the patient to rate the care provided by the ASC and the patient’s willingness to recommend the ASC to family and friends. They are:


■ ■


ASC-15d: OAS CAHPS—Overall Rating of Facility; and


ASC-15e: OAS CAHPS—Recom- mendation of Facility.


ASC-15d asks the patient to rate the


care provided by the ASC on a scale of 0 to 10, and ASC-15e asks about the patient’s willingness to recommend the ASC to family and friends on a scale of “Definitely No” to “Definitely Yes.” ASC performance on each of the two global OAS CAHPS survey-based mea- sures would be calculated by proportion of


respondents providing high-value


responses (that is, a 9-10 rating or “Def- initely Yes”) to the survey questions over the total number of respondents.


Risk Adjustment CMS will perform a risk adjustment on the collected data to account for factors not directly related to ASC per- formance, such as patient case mix, to achieve the goal of fair comparisons across all ASCs. The survey-based measures are adjusted for patient char- acteristics such as age, education, over- all health status, overall mental health status, type of surgical procedure and how well the patient speaks English. These factors influence how patients respond to the survey but are beyond the control of the ASC and are not directly related to ASC performance.


Public Reporting of Data This data will be made publicly avail- able on the Hospital Compare web site where other ASCQR Program data is currently found. CMS will propose a format and timing for public report- ing of OAS CAHPS survey data in future rulemaking prior to implemen- tation of the measures. It is unclear whether CMS plans to compare data between ASCs and HOPDs, but that is something ASCA will comment on in future rulemaking.


Kara Newbury is ASCA’s regulatory counsel. Write her at knewbury@ascassociation.org.


ASC FOCUS APRIL 2017 21


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