EXECUTIVE SUMMARY
The Centers for Medicare & Medicaid Services (CMS) will require ambulatory surgery centers (ASCs) to conduct patient experience surveys through certified vendors, as of Jan. 1, 2018.
- Each survey contains 37 required questions, with up to 15 optional questions set by the center.
- The approved modes of delivering surveys are paper and telephone calls, or a combination of the two.
- The Ambulatory Surgery Center Association has asked CMS to delay implementation and provide an electronic survey option.
A Hickory, NC, surgery center’s experience with patient satisfaction surveys is fairly typical. The organization sends an automatic email link to patients after discharge. Those who respond answer 10-12 questions, ending with the question, “Would you recommend this facility?” The whole process could take five to 10 minutes.
“All the results are calculated and sent back to us on a monthly and quarterly basis. They’re summarized into the quarterly report, too,” says Kathy Kelly, RN, MSN, CNOR, administrator of Viewmont Surgery Center in Hickory.
This soon will change. The Centers for Medicare & Medicaid Services (CMS) is requiring ambulatory surgery centers (ASCs), as of Jan. 1, 2018, to conduct patient experience surveys either on paper or by phone, or a combination of both. They must use one of 21 CMS-certified vendors, and an electronic option is not yet available. Each survey contains 37 questions required by CMS, and each ASC can add up to 15 of their own. As of late May, the deadline was intact, although it could be postponed or cancelled by CMS. ASCs must report quality of care data for standardized measures to receive the full annual update to their ASC annual payment rate.
It’s called the OAS CAHPS, which stands for the Outpatient and Ambulatory Surgery Survey and the Consumer Assessment of Healthcare Providers and Systems. HHS began developing the survey in 2012 and provided opportunities for ASCs and others to comment on the proposed rule. The ASC Quality Collaboration, which spearheads measure development activities for the industry, was involved throughout the survey development process. The collaboration proposed ways to shorten the survey and make its administration less burdensome for facilities, says Kara Newbury, JD, regulatory counsel for the Ambulatory Surgery Center Association (ASCA) of Alexandria, VA.
“The ASC QC and ASCA are aligned in our desire to promote a patient satisfaction survey that provides meaningful data to patients, ASCs, and CMS,” Newbury says.
A 37-question survey would be a very long survey to fill out by mail or to answer by phone, she adds.
“Most facilities currently use a patient satisfaction form that is much shorter than this, and they probably include questions more specifically geared toward patient satisfaction — as opposed to patient experience,” Newbury says. “Some people don’t understand the difference between the two, but there are different ways those questions are written.”
Experience and satisfaction are not the same, as CMS notes in CAHPS.
“Patient experience surveys sometimes are mistaken for customer satisfaction surveys,” Newbury says. “Patient experience surveys focus on how patients experienced or perceived key aspects of their care, not on how satisfied they were with their care.”
For instance, a patient satisfaction survey might ask patients to rate their pre-op nurse on a scale of one to five. A patient experience survey might ask patients whether or how they experienced critical aspects of health care, including communication with their doctors, understanding their medication instructions, and the coordination of their healthcare needs. “They do not focus on amenities,” Newbury says.
The focus on patient experience might work well, but ASCs have reason to worry about the survey’s length and lack of an electronic option. People are so accustomed to the convenience of electronic surveys that a paper or telephone survey might not deliver the same response rate. Plus, an electronic survey would be less costly to ASCs, Newbury notes.
The OAS CAHPS Survey — for both mail and telephone administration — is available in English, Spanish, and Chinese, according to the protocols and guidelines manual on the OAS CAHPS website.
Hospital outpatient and ambulatory surgery sites are not permitted to translate the survey into other languages, but CMS will provide additional translations over time, Newbury says.
If patients being surveyed are concerned about the confidentiality and privacy of their information and responses, survey vendors can reassure them that no responses are linked to an individual patient and participation in the survey will not affect the care or health care benefits they receive, according to the confidentiality and data security section of CMS’ OAS CAHPS’ protocols and guidelines manual.
CMS was concerned that some patients would not have email or the skills needed to access an electronic form, she notes.
“I disagree with that,” Newbury says. “I have data from [some older] members. It doesn’t matter the age group. The success rate for electronic forms is pretty good.”
Viewmont Surgery Center’s survey response rate has trended upward to about 35% this past year, Kelly says. “I definitely think that response rate would go down if the form was longer.”
The trouble is that CMS is requiring ASCs that perform 240 Medicare cases per year to collect 300 completed surveys. If their response rate is low, this means they’ll need to survey many more patients than they might otherwise survey. They can survey any patient, including non-Medicare patients. And if the facility does not think it’s possible to achieve 300 completed surveys, it must survey all eligible patients, Newbury notes.
ASCA sent a letter, signed by ASCA CEO Bill Prentice, to U.S. Secretary of Health and Human Services (HHS) Tom Price, MD, on April 21, requesting relief from the regulatory burden associated with the OAS CAHPS.
“While we strongly support quality reporting, we fear that the cost and administration burdens associated with this survey may discourage ASCs from participating in the Medicare program,” the letter reads.
ASC also asked Price to consider adding an electronic survey option to the paper and phone methods approved by CMS. The new rule would cost the average ASC about $6,000, Newbury says.
“Once an electronic option is approved, this will significantly cut down on the costs for our facilities, and provide more actionable data since the number of patients surveyed can be increased exponentially,” the letter reads.
ASCs might be more willing to collect more than the minimum number of completed surveys required if the cost per survey were not as high as it is with the telephone and paper surveys, Newbury says.
“ASCA has been advocating for many different things with regards to the survey, but specifically for the survey to be made shorter,” she says. “And we’ve advocated for an electronic option.”
At the very least, ASCA hopes HHS will delay the survey’s implementation.
“We believe that Secretary Price, being an orthopedic surgeon by background, understands the burden this could place on our facilities,” Newbury says. “We are optimistic that we might get some reprieve, whether it be a short delay, or they re-evaluate the length of the survey, or they allow an electronic option.”
One positive change related to the OAS CAHPS is that ASCs will be able to compare themselves to hospital outpatient departments, since everyone will be using the same survey, says Kathy Wilson, RN, MHA, vice president of quality for AmSurg.
“That’s something we have not been able to do before,” Wilson says.
AmSurg participated in a CMS pilot of the new survey in 2014. The organization already had been using paper surveys, so that wasn’t an issue, Wilson says.
“We are able to talk to patients and say they may receive a survey, and it’s important to us to gather that information from them,” she says. “Sometimes, if you connect with patients ahead of time and tell them why it’s important to you, they may be more apt to fill it out.”
CMS voluntarily collected data with 100 facilities, and the overall response rate was 39%, Newbury says.
“The results were higher than I would think you would get with such a cumbersome long form,” she adds.
Vendors will handle most of the work necessary to make the surveys successful. But ASCs will need an information technology expert to help with the initial task of uploading the file to the survey vendor. The patient lists can be submitted electronically, but there is some work necessary to get the reports built, Wilson says.
“You have to meet file specifications that come from the survey vendor, and you have to build a report out of a billing system to meet those filing specifications,” she explains. “An IT person, working with the billing vendor, can bridge the billing vendor with the survey vendor.”
Some ASCs will take the rest of 2017 to find a survey vendor and get started on a voluntary, pilot basis with the change. Others will wait and see if HHS will announce a delay to implementation, Newbury says.
All ASCs should at least explore the new survey process and learn what they can do before committing to a vendor, she adds.
“The questions asked in the new survey are vastly different, so learning how patients are going to respond to the questions in this survey might take some time,” she says.
“We’re very supportive of quality reporting, and we’re not opposed to some sort of survey that will allow patients to compare across sites of service,” Newbury says. “We’re just not sure — given lengths and modes of operation — whether this is the appropriate tool.”
The Centers for Medicare & Medicaid Services will require ambulatory surgery centers to conduct patient experience surveys through certified vendors, as of Jan. 1, 2018.
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