EDITOR’S NOTE: This article was written prior to the July 13, 2017 CMS notification that the OAS-CAHPS survey will be delayed and the anticipated Jan. 1, 2017 mandate will be postponed. According to a subsequent press release from the Outpatient Ophthalmic Surgery Society (OOSS), “CMS is proposing to delay the mandatory implementation of the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS) under the ASCQR Program for CY 2018 data collection. For years, OOSS has raised serious concerns with respect to the size and content of, and administrative and financial burdens associated with, the survey and joined the ASC community in lobbying for delay in requiring that facilities participate.” In addition to OOSS, the OAS-CAHPS.org website published the following update on July 14, 2017, “In this proposed rule, CMS proposes to delay implementation of the OAS CAHPS Survey Based Measures beginning with the CY 2020 payment determination (2018 data collection) until further action in future CMS-1678-P 477 rulemaking. CMS will continue to analyze the national implementation data and consider any necessary modifications to the survey tool and/or CMS systems.” In consideration of the delay, the authors of this article believe that the advice contained herein is still applicable to the proposed rule, presuming that it ultimately takes effect and, furthermore, that HOPD or ASC administrators choosing to be proactive in patient/consumer surveys will find the content useful for CMS mandated surveys. At the time of this publication, it is unclear as to when, or if, a new date will be released.

While recently delayed, ultimately it is still possible that any ASC that sees 60 or more eligible patients per year will need to contract with a Centers for Medicare and Medicaid (CMS)-approved vendor to administer the Outpatient and Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS) Survey.

Despite the delay (and possible major changes or even total elimination), it is important to be proactive when confronted with regulatory change. This article was written to encourage and inspire ASC owners and managers to use the now-extended voluntary time to prepare for OAS CAHPS, so they will be in the best possible position when a final ruling takes place.

Why Consider Early Participation?

Although the OAS CAHPS program is already open for voluntary submissions in 2017, very few ASCs have taken the plunge. However, Albert Castillo, CEO of San Antonio Eye Center, is moving his surgery center toward compliance. He admits that, like most ASC directors, he was putting it off quite simply “because there was time.” Yet, he figured there might be trouble if he waited much longer because of the limited number of approved vendors compared with the large number of surgery centers and hospital outpatient departments (HOPDs) that will be required to participate.

“Most likely, the vendors will be overwhelmed, presuming most centers will wait until mandatory participation is required,” Castillo says.

Certainly, centers may choose not to participate in the survey at all. As with most CMS quality-related programs, this program levies a future penalty based on the center’s reporting. In this case, centers that do not participate in OAS CAHPS would potentially forgo 2% of their annual Medicare payment update. For this reason, most center directors say they will participate. However, few have felt the need to start early with the voluntary reporting. Prior to the most recent announcement delaying the Jan. 1, 2017 reporting mandate, Kent Jackson, executive director for the Ophthalmic Outpatient Surgery Society (OOSS), estimated that 50 member centers had begun the voluntary process, either through a new partnered program with Fields Research that gives discounts to OOSS members that start early or through other vendors.

There may be several advantages to voluntary survey submission in 2017 and 2018. First, as Castillo indicates, centers will have more time and attention from the vendors to set up the processes correctly before they face a potential year-end crunch. Additionally, centers will have additional time, if necessary, to make adjustments to their internal reporting systems and processes.

Todd Albertz, vice president of surgical and specialty services at Cincinnati Eye Institute, recently started the voluntary survey process, citing the importance of gaining experience.

“Participating now allows us to learn from the feedback and be in a better place once the mandatory period begins,” Albertz says.

Press Ganey, a large survey vendor approved by CMS, has worked with hospitals to implement CAHPS. In doing so, it saw that clients that started the program early during the voluntary phase outperformed those that waited until reporting became mandatory.

Steps to Get Started

ASC managers are used to breaking down big projects into manageable steps to get from start to finish. Here are our recommended steps to make sure your ASC will be compliant in a timely manner.

Step 1: Do the Research

Understand the actual requirements of the program. This will ensure you are asking the right questions and not wasting time on processes that won’t matter. Vendors will provide frequently asked questions to consider, and other center leaders who have done research may share their findings. The best place to start your research is on the CMS website (oascahps.org ), where there are valuable links, instructions, and materials available. Also, you may email AmbSurgSurvey@cms.hhs.gov.

Step 2: Identify Resources

You will be able to find a consultant to manage the project for you if you don’t have the time to complete the project yourself. Of course, there is an expense associated with hiring a consultant.

Another option would be to look to your industry associations for resources available to support your center. Both the Ambulatory Surgery Center Association (ascassociation.org ) and the OOSS (ooss.org ) have guidance tools, as well as strong vendor relationships, which centers may find useful in their decision-making process.

As mentioned previously, prior to the delay, OOSS announced a special arrangement with a survey vendor Fields Research that will greatly reduce cost and encourage centers to enroll in the voluntary program.

The vendors themselves are also good resources, although completing your research before contacting them will help you ask the right questions of the vendors. A list of CMS-approved vendors is available at hoascahps.org/General-Information/Approved-Survey-Vendors . We understand there are more approved vendors than the 23 on this list, which was current as of April 17.

Step 3: Choose a Vendor

Projections indicated that a mandatory program will have a significant monetary impact on annual vendor expense to the ASC (estimated today at $7,000–$14,000). This does not account for staff time to maintain compliance, as well. Therefore, it is critical to choose the right vendor partner. Table 1 provides questions and considerations to help a center interview vendors.

Step 4: Create a Task Force and Develop the Project Plan

As with any project, implementation will go more smoothly if those tasked with performing the ongoing reporting are involved throughout the process. Help the team create a project plan to mark milestones and identify who oversees the different steps with vendor guidance (and, perhaps, a template action plan). Once the project plan is completed and approved, begin the implementation process. Remember to communicate with the entire center staff throughout the project — not only about the survey process itself but also the long-term satisfaction results — to ensure success.

“We have provided the questions to our general staff, anesthesia staff, surgeons, and surgery schedulers so that everyone knows what patients will be questioned about,” Albertz says, when describing his communication with the team.

Probably the hardest part of the CMS survey is the fact that it is out of the hands of the center once everything is turned over to the vendor. “If we complete all our steps and turn the patient information over to the vendor and they get zero responses, our center has still complied,” Castillo says. He indicates that this is another reason why vendor selection is critical, as there are no real compliance requirements on the vendor’s end. Vendors must send out a number of surveys based on the patient list, but they don’t have to achieve a response rate. The proposed CMS target number of responses (300) is not mandatory.

Step 5: Monitor and Improve

Since patient satisfaction surveys have long been a part of ASC quality improvement programs and certification requirements, most ASCs are already conducting their own independent patient satisfaction surveys. Patient feedback indicates areas of improvement, and centers act on those suggestions. With the proposed CMS survey process, centers may need to decide whether to continue their existing satisfaction program or simply use the OAS CAHPS program.

It is difficult to say what type of responses and results will be available, given the delay. For this reason, Castillo plans to continue with his own satisfaction survey. His center uses a brief, eight-question survey that patients can complete during recovery or mail back to the center from home.

“We have about a 90% response rate,” says Castillo, who doesn’t want to give up the quality feedback the center collects from its current process.

Meanwhile, Cincinnati Eye is planning to discontinue its current process. “We perform more than 14,000 cases per year,” Albertz explains. “Between processing and postage for those surveys, we feel that eliminating them will offset the cost of the OAS CAHPS Survey.”

Be Informed and Prepared

Although the deadline for reporting into the mandatory OAS CAHPS Survey has been delayed and a mandated date for compliance with the OAS CAHPS has not been provided, history tells us that a delay doesn’t mean that this will simply “go away.” Proactive ASCs will budget and plan ahead in the event this survey is implemented in the future. ■