HOPD: A unit of a hospital whose primary focus is to perform outpatient surgeries and procedures, is Medicare-certified, has a CMS Certification Number (CCN), and bills CMS under the Outpatient Prospective Payment System (OPPS).
ASC: A freestanding medical facility that performs outpatient surgeries and procedures, is Medicare-certified, has a CCN, and meets the general conditions and requirements in accordance with 42 CFR 416 subpart B.
ASCs and HOPDs are encouraged to voluntarily participate in 2017. Beginning January 1, 2018 mandatory participation will be required for all ASCs and HOPDs who have performed at least 60 surgeries or procedures in 2017.
Yes there is a penalty. ASCs and HOPDs that exceed the minimum 60 surgery/procedures in calendar year 2017, and neglect to participate in OAS CAHPS in 2018 will see a 2% cut in all reimbursements in 2020, and in subsequent years for which they are out of compliance.
The only ASCs and HOPDs exempt in 2018 are those that have performed less than 60 surgeries or procedures in 2017
The goals for designing the survey include producing a standardized instrument for generating data which:
The survey contains 37 questions that allow patients to rate their service on the topics of communication and care provided by health care providers and office staff; preparation for the surgery or procedure, and preparations for discharge and recovery. All these topics are important to patients when choosing an outpatient or ambulatory surgery provider.
Patients that are at least 18 years old with at least one outpatient surgery/procedure (including overnight observations patients not admitted), received in a Medicare certified HOPD or ASC. The patients must have undergone a surgery/procedure on a list of approved CMS CPT and G codes in the OAS CAHPS Protocols and Guidelines Manual. All these patients qualify regardless of their payor source.
Survey Eligible CPT and G codes
CPT: Code in the 10021– 69990 range without accompanying modifier of 73 or 74 (discontinued procedure).
G Codes: Procedures that are HCPCS Screening Codes G0104, G0105, G0121, or G0260
Patients are contacted utilizing 3 approved methods - mail-only, telephone-only, and mixed mode (mail survey followed by telephone)
Survey vendors typically provide various reports of patient surveys to facilities. The data submitted by approved vendors will be made available to facilities in a preview report, 3 months prior to public reporting on the CMS website. Participating facilities will also need to have a minimum of 4 consecutive quarters worth of data to have their results reported on the CMS Medicare compare websites and compared against state and national averages.
The survey is accessible for download in English, Spanish, Chinese, Korean.
CMS set an annual target of 300 completed surveys for each HOPD or ASC, and approved survey vendors are required to calculate a sampling rate to reach that target, which is relatively easy for larger organizations. However organizations with a smaller number of surgeries/procedures are not penalized for not reaching the 300 survey target. Facilities are encouraged to exceed this target to gain additional insights and engagement with patients.
No, an OAS facility cannot administer the OAS CAHPS survey, and submit the results to CMS. The OAS CY 2017 Final Rules clearly outline that independent CMS approved vendors are the only ones that can administer surveys on behalf of the OAS facility and submit to CMS. Facilities are able to add custom questions to the standardized instrument, although there may be an associated cost from approved CAHPS vendors.
No, an OAS facility is unable to become approved by CMS as an OAS CAHPS vendor. The business requirements for becoming an approved OAS CAHPS vendor preclude an organization that owns, operates or provides staffing for an HOPD or ASC from applying. Survey vendors are also required to prove they are experienced in conducting surveys in the approved modes - mail-only, telephone-only, and mixed-mode (mail followed by telephone) and a number of other requirements.
Participating early will allow the OAS to learn more about administering the survey, and get a jump start on using the generated results to improve patient engagement efforts prior to when it becomes mandatory in 2018.