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 measures would be cal- culated by the proportion of respon- dents providing high-value responses (that is, a 9-10 rating or “definitely yes”) to the survey questions over the total number of respondents.

Risk Adjustment CMS believes it is necessary to adjust for factors that are not directly related to ASC performance, such as patient case- mix, to achieve fair comparisons across all ASCs. The survey-based measures are adjusted for patient characteristics such as age, education, overall 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. Therefore, as part of the calculations, CMS will perform a risk adjustment on the collected data.

Public Reporting of Data The data will be made publicly avail- able on the Hospital Compare web site, where the other ASCQR Program data is currently found. CMS will propose a format and timing for public reporting of OAS CAHPS survey data in future rulemaking prior to implementation of the measures. It is unclear whether CMS plans to compare data between ASCs and HOPDs, and ASCA plans to com- ment on that idea in future rulemaking.

Concerns with the OAS CAHPS Survey The ASC Quality Collaboration (ASC QC), which spearheads measure devel- opment activities for the industry, has been involved since the beginning of the survey development process and proposed ways to shorten the sur- vey and make its administration less burdensome for ASCs. The ASC QC


and ASCA are aligned in their desire to promote a patient satisfaction sur- vey that provides meaningful data to patients, ASCs and CMS. It is impor- tant that CMS address some of the industry’s key concerns, including the following, to alleviate burden and encourage participation. ■

making the survey even longer, it is important that the means by which patients complete the survey is as user-friendly as possible.

The lack of use of information tech- nology is a hindrance and increases burden unnecessarily. Internet access and email accounts are common in today’s society and should be, at least, allowed as an option for data collec- tion. Particularly if facilities would like to include their own measures,

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Visit ASCA’s web site every week to stay up to date on the latest government affairs news affecting the ASC industry. Every week, ASCA’s Government Affairs Update newsletter is posted online for ASCA members to read. The weekly newsletter tracks and analyzes the latest legislative and regulatory developments concerning ASCs. GovtAffairsUpdate

The expected number of 300 com- pleted surveys might be overly bur- densome for facilities. When inpa- tient hospitals were first required to use the HCAHPS survey, they had to have at least 100 completed surveys. Setting higher expectations from the start for smaller providers like ASCs is unreasonable.

The survey should be significantly shortened,

focusing on actionable

aspects of the patient experience in the outpatient setting and essen- tial demographic data. The hospi- tal survey is currently 32 questions long, compared to the 37 questions in the OAS CAHPS. Considering patients in an outpatient setting leave the facility in less than 24 hours, it seems that fewer questions are war- ranted than in the inpatient setting. ASC QC and ASCA will com- ment on these and other points in their responses to the proposed rule and will continue to monitor and provide feed- back on any future rulemaking.

Kara Newbury is ASCA’s regulatory counsel. Write her at

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