REGULATORY REVIEW


one follow-up mailing if they fail to respond within three weeks.


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Telephone-only: Participants in this group will be called a maximum of five times.


Mixed mode (mail survey with tele- phone follow-up of non-respon- dents): Participants in this group will be sent one letter, and then, if they fail to respond, will be called a maximum of five times. Although counterintuitive in this digital era, to date, CMS has not seri- ously considered adding an electronic data collection option, stating that an email contact is difficult to obtain from patients. CMS does not indicate why phone numbers would be more readily available than email addresses.


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Next Steps This year, CMS will conduct a mode experiment at 50 HOPDs and 50 ASCs to determine if the patients respond dif- ferently to the survey depending on the mode used to administer it, i.e., telephone only, mail only or mixed mail and telephone. CMS anticipates data from these facilities will be col- lected during fall 2015. According to CMS, “this one-time survey prior to the national implementation of OAS CAHPS is crucial for determining dif- ferences in survey responses based on the three modes of data collection and to determine patient characteristics that might affect experiences and the rat- ings of the care they receive.” For this initial study, CMS will pay the third- party vendors for the data collection. In 2016, CMS plans to roll out a


voluntary program in which ASCs and HOPDs can choose to report OAS CAHPS data to CMS and whether to publicly report data. ASCs and HOPDs will be invited to participate in the national implementation of OAS CAHPS by contracting with a CMS- approved, third-party vendor of their choosing to implement the survey on their behalf and submit the OAS CAHPS data to CMS. CMS is expect-


ASC community’s key concerns with the current study to alleviate the bur- den it imposes on ASCs and encourage participation. Those concerns include: ■


ing a minimum of 300 completed sur- veys per facility each year.


The lack of use of information tech- nology is a hindrance and increases burden unnecessarily. Internet access and email accounts are com- mon in today’s society, and, at a minimum, should be allowed as one option for data collection. Par- ticularly if facilities would like to include their own questions, mak- ing the survey even longer, it is important that the means by which patients complete the survey is as user-friendly as possible.


During


this stage, facilities will be required to pay for the data collection through the third-party vendors. 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 improvement efforts, and will help CMS monitor the performance of outpatient surgery facilities.”


ASC Concerns about the Survey The ASC Quality Collaboration (ASC QC), which spearheads quality mea- sure development activities for the ASC community, has made detailed recommendations when opportunities for public comment have been offered during the OAS CAHPS Survey devel- opment process. In its comments, the ASC QC proposed ways to shorten the survey and make its administration less burdensome for ASCs. The ASC QC and ASCA are aligned in a desire to promote a patient experi- ence survey that provides meaningful data to patients, ASCs and CMS. To achieve that goal, both organizations are asking CMS to address some of the


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The expected number of 300 com- pleted surveys is inequitable with the CAHPS surveys being conducted by other providers. For example, to be in compliance with HCAHPS sur- vey data collection, hospitals must have 100 completed surveys. Setting higher expectations for smaller pro- viders like ASCs is unreasonable.


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The survey should be shortened significantly,


focusing on action-


able aspects of the patient experi- ence in the outpatient setting and essential demographic data. The OAS CAHPS survey is currently 37 questions long, while the hospital survey contains 32 questions. Con- sidering that patients in an outpa- tient setting leave the facility in less than 24 hours, it seems that fewer questions are warranted than in the inpatient setting.


Future Implications It is unclear when measures based on the OAS CAHPS will be incorporated into the CMS ASC Quality Reporting Program. The ASC QC and ASCA will continue to monitor CMS progress toward national implementation and provide feedback as opportunities present themselves.


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


ASC FOCUS AUGUST 2015 21


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