Archive July 2017 XVIII, No. 7

Editor's Page: When Quality Reporting Becomes Burdensome

Patient satisfaction surveys could be more trouble than they're worth.

Dan O

Dan O'Connor

BIO

The OAS CAHPS CMS survey is a bureaucrat's delight. Everything about it is overdone and overbearing, from its clunky 11-word name to its 37 questions — many of which are highly intrusive of your patients' personal information — to its threat to withhold 2% of your Medicare reimbursement as penalty for not complying with a voluntary quality reporting program that becomes mandatory for all ambulatory surgery centers and hospital outpatient departments on Jan. 1 — unless, of course, Medicare finds reason to push back the start of the survey known as the ... deep breath ... Outpatient and Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems by 100 or so days.

Just what you need, says healthcare attorney Mark F. Weiss, "forced compliance with yet another governmental program imposed on already overworked ASC administrators and staff."

"Are Your Ready for OAS CAHPS?" on page 60 answers many of the questions you might have about the satisfaction survey that asks your patients about nausea, bleeding, pain, infection and discharge instructions. Survey response options are Yes, Definitely; Yes, Somewhat; and No.

But in typical bureaucratic fashion, how patients answer doesn't really matter. OAS CAHPS is pay for reporting, not pay for performance. What matters to CMS is whether you meet the data submission requirements, not the score. Yes, your score will be publicly reported and one day CMS might apply its hospital star rating system to surgery centers based on quality reporting, but all CMS cares about is that, starting in 2018, you complete 300 surveys in a year.

"The entire quality reporting system is still only pay for play, not (yet, anyhow) pay for performance. Sort of like pass/fail," says David Shapiro, MD, vice chairman of the ASC Quality Collaboration.

Mr. Weiss and Cecilia Kronawitter, a surgery center developer, are harsh critics of OAS CAHPS.

"The expense of mandatory reporting and the 2% penalty for noncompliance are just the start of the true cost of OAS CAHPS," they say. "The rest is an instantiation of President Reagan's quip that the 9 most terrifying words in the English language are, I'm from the government and I'm here to help."

They find fault with who'll conduct the patient surveys: not you or someone from your staff but a CMS-approved vendor who'll charge you anywhere from $10 to $25 per completed survey.

"You must give the vendor your patients' personal information. The vendor's staff will contact your patients and conduct the survey for you," they say. "What a vendor might charge, and how they might charge — for each completed survey, for each partially completed one, for each phone call? — is determined by that particular vendor."

What's most troubling to Mr. Weiss and Ms. Kronawitter is the highly personal, non-medical nature of more than one-third of the 37 questions.

  • In general, how would you rate your overall mental or emotional health?
  • Do you speak a language other than English at home? If the patient answers "yes," then the patient must name the language.

"These questions aren't about your ASC, they're about data mining your patients," they say. "How many patients will actually give up all of the required information in order to have their responses count as completed surveys?"

The real worry is if quality reporting becomes too burdensome, if it takes too much of your time and your money, then some could decide not to participate and concede the 2% reimbursement update — especially at facilities that don't do a lot of Medicare.

Further, when OAS CAHPS becomes a pay-for-performance survey tool and is tied to payment, still more could stop reporting if they start getting dinged. We've already seen this with hospitals that have stopped reporting thier readmission rates. OSM

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