REGULATORY REVIEW


Although it seems counterintuitive in this digital era, to date CMS has not seriously considered adding an electronic data collection option. After facilities have collected data for 12 months, CMS will begin pub- licly reporting comparative results from OAS CAHPS. According to CMS, OAS CAHPS measures will “enable consumers to make more informed decisions when choosing an outpatient


surgery facility, aid


facilities in their quality improve- ment efforts, and will help CMS monitor the performance of outpa- tient surgery facilities.”


2017 Proposed Rule


CMS is proposing to adopt five sur- vey-based measures derived from the OAS CAHPS survey for data collec- tion beginning in calendar year (CY) 2018, which impacts payment deter- minations in CY 2020. There are three OAS CAHPS composite sur- vey-based measures, which consist of six or more questions. Those mea- sures are: ■


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


■ ■


ASC-15b: OAS CAHPS—Communi- cation About Procedure; and


ASC-15c: OAS CAHPS—Preparation for Discharge and Recovery. The two global survey-based mea-


sures consist of a single question each and ask the patient to rate the care provided by the ASC and their will- ingness to recommend the ASC to family and friends. They are: ■


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


ASC-15e: OAS CAHPS— Recommendation of Facility. If CMS’ proposal is finalized ASCs will be required to contract with a CMS-approved vendor to collect sur- vey data for eligible patients at the ASCs monthly and report that data to CMS on the ASC’s behalf by quarterly deadlines established for each data col- lection period. ASCs may elect to add up to 15 supplemental questions to the OAS CAHPS Survey.


■ 26 ASC FOCUS OCTOBER 2016


CMS, seeing value in standardization, has proposed to mandate use of the OAS CAHPS, which would measure patients’ experience of care within both HOPDs and ASCs. If finalized as proposed, facilities would be required to begin using the survey in 2018.”


—Kara Newbury, ASCA


Survey Cohort The OAS CAHPS Survey is adminis- tered to all eligible patients—or a ran- dom sample of eligible patients—— regardless of the patients’ insurance or method of payment. For purposes of each survey-based measure captured in the OAS CAHPS Survey, an eligi- ble patient is a patient 18 years or older who visited an ASC during the appli- cable month and: ■


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 the ASC not release their name and contact information to anyone other than ASC personnel.


In addition, patients whose address is not a US domestic address cannot be surveyed (because of state regula- tions) and patients who are deceased are ineligible.


Sampling Requirement and Low-Volume Accommodations ASCs would be required to survey a random sample of eligible patients on a monthly basis and collect at least 300 completed surveys over a 12-month reporting period. CMS recognizes that smaller ASCs might not be able to collect 300 completed surveys dur- ing a 12-month period. ASCs that treat


fewer than 60 survey-eligible patients during the year preceding the data col- lection period can submit a request to be exempted from performing the OAS CAHPS survey. Smaller ASCs that cannot collect 300 completed sur- veys over a 12-month reporting period but are above the low-volume thresh- old would be required to collect only as many completed surveys as possi- ble during that same time period and to survey all eligible patients rather than a representative sample. For all measures in the ASC Quality


Reporting (ASCQR) Program, facilities are exempt from participation if they bill fewer than 240 Medicare primary and secondary claims in a year. It is unclear how the current 240-claim low-volume threshold impacts the OAS CAHPS requirement, and ASCA is seeking clari- fication from CMS.


Measure Calculations As noted above, CMS is proposing to adopt three composite OAS CAHPS survey-based measures (ASC-15a, ASC-15b and ASC-15c) and two global survey-based measures (ASC-15d and ASC-15e). As with all other measures currently in the ASCQR Program, an ASC’s performance for a given pay- ment determination year will be based upon the successful submission of all required data, not on the content of the submitted data. The data, however, will become public and available to poten- tial patients to use to determine how one facility compares to another.


Composite Survey-Based Measures ASC rates on each composite OAS CAHPS Survey-based measure would be calculated by determining the pro- portion of “top-box” responses (that is, only counting the “yes” or “yes defi- nitely” answers) for each question within the composite and averaging these proportions over all questions in the composite measure.


Global Survey-Based Measures The two global measures are based on only one question each. ASC-15d asks


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