The first letters of non- compliance notification have begun arriving to over 1300 agencies. Many agencies are complaining they had complied. What has occurred? What should an agency leader do after receipt of such a letter? Why is there such focus on this survey?
What is the CAHPS Program?
The Consumer Assessment of Healthcare Providers and Systems is designed to develop and support the use of comprehensive standardized surveys that ask customers and beneficiaries to report on and evaluate the care they received. The program is funded by and administered by the US Agency for Healthcare Research and Quality (AHRQ). For over a decade CAHPS has established principles that include identifying and supporting consumer information, adherence to scientific testing principles, comparability of data, as well as maintaining products in the public domain. (CMS, AHRQ, CAHPS).
CAHPS surveys are standardized per AHRQ in the following manner:
The Instrument is standardized in such a fashion that anyone administering the survey can ask the questions in the same way.
The protocol is standardized in that it adopts the same approach to “drawing the sample, communicating with potential respondents, and collecting the data.”
The analysis is developed in a way to minimize variations in how vendors process and interpret survey results.
The reporting uses a well-tested approach that reflects best practices in reporting.
How is CAHPS Data Utilized?
Health care monitoring agencies, such as State regulatory agencies and Quality Improvement Agencies (QIOs) use CAHPS data coupled with quality measure data to evaluate agency performance. Since 1999, the National Center for Quality Assurance (NCQA) has required CAHPS data from health plans that are seeking accreditation or when they submit data as part of the Health Plan-Employer Data and Information Set (HEDIS). Behavioral health organizations must use CAHPS data along with their ECHO survey when they are seeking accreditation. PPOs must have CAHPS survey findings completed routinely as part of their accreditation process through URAC.
The CAHPS standardized surveys are expanding into new areas of healthcare but CAHPS is not new to the business of surveys. CAHPS Health Plan Surveys are designed to be heterogeneous in population coverage.
Per CMS, CAHPS Emphasis is on Consumers and Patients
CMS believes that “consumers and patients are the best and/or only source regarding care.” They also state that CAHPS surveys do not attempt to collect information that can be gathered more effectively through other means. This overall program has been a successful collaboration of public and private research organizations that includes RAND, Yale School of Public Health, and the American Institute for Research. Together, the private and public groups are known as the CAHPS Consortium. Together, they have been instrumental in developing and testing ways organizations can use CAHPS data for quality improvement.
Can an Agency Improve their Scores Through Better Practice?
Yes, an agency not only can influence later scores, they should be aggressive in doing so. Reward clinicians when a positive comment is known. In the same regard, keep track of negative comments. Help the clinician who is perceived as lacking in customer service attributes. Review facts such as sitting with a patient for 1-2 minutes creates an image of spending time and not being in a hurry. Taking time to ask about a grandchild or a pet conveys sensitivity and caring. Sometimes, a busy very qualified clinician can have behaviors misunderstood.
Be certain that clinicians understand that research supports the fact that patients want at least a day’s notice of a visit. Timely notification scores decline if the clinician does not establish or remind the patient of the visit at least one day in advance.
Find creative ways to help patients remember their education. When I once visited a home to survey care, the patient showed the picture of the blue ribbon she had received for correctly learning how to properly administer her meds. She and her nurse had a fun time discussing the fact that she had always wanted a blue ribbon. “Now, I have one,” she stated.” And later she challenged me. “Ask me anything about those meds,”
Patients who are visual learners may appreciate a journal to take notes or may appreciate printed information they can underline with colored markers. The important point is learning how they have learned in the past.
Return phone calls promptly (within 10-15 minutes) to obtain high scores on timeliness of response to questions.
The First HHCAHPS Letters of Non-Compliance have been Received
Over 1300 agencies have received letters notifying them that they have not satisfied the requirement for participation in HHCAHPS. As a result, these agencies are slated to have a 2% market-basket reduction in 2012. That 2% will be in addition to the 3.5% payment cut proposed by CMS for that year. In a time of fragile bottom lines, a 5.5% reduction can be onerous.
So, what should the agencies do if they receive the letter of non-compliance and they believe it was sent in error? Consider appeal! Be prompt. The letter of non-compliance has a 30 day life span for appeal. Do not miss it. Verify with your vendor that the required data was submitted timely. Ask for proof of transmission.
Many agencies that received the letters reported to NAHC that submission of data occurred. Obtain proof from your vendor of the dry run and the ongoing data submissions. Data submission guidance can be found at https://homehealthcahps.org/HHAGuidanceforDataSubRept.pdf
Some agencies believe CMS may have a glitch in the reporting system. Take no chances. Obtain proof from your vendor of submission and preserve your rights by filing the timely appeal. Be proactive. The old adage, “not to decide is to decide… is true” Decide and Act.