Published on:

Requirements for the Home Health Care CAHPS Survey

The Consumer Assessment of Healthcare Providers and Systems (CAHPS) Home Health Care Survey is designed to measure the experiences of individuals receiving home health care from Medicare-certified home health care providers. The CAHPS has three broad goals: (1) to produce comparable data on the patient’s perspective that allows objective and meaningful comparisons between home health agencies on domains that are important to consumers; (2) public reporting of survey results so as to create incentives for agencies to improve their quality of care; and (3) public reporting to enhance public accountability in health care by increasing the transparency of the quality of care provided in return for public investment.

The home health care CAHPS (HHCAHPS) survey began in October 2009 with agencies that wished to implement the survey on a voluntary basis. The data collected during the voluntary period will be posted in Spring 2011. Agencies will have the option to suppress the reporting of their data collected during the voluntary period.

However, the Home Health Prospective Payment System (HHPPS) Final Rule (November 10, 2009) stated that HHCAHPS will be linked to the quality reporting requirement for the CY 2012 annual payment update (APU). The Centers for Medicare & Medicaid Services (CMS) strongly encourages that the designated quality staff in all Medicare-certified home health agencies (HHAs) read the Final Rule.

The HHCAHPS requires the following: (1) data collection must start in the third quarter of 2010 in the form of a practice “dry run” of the survey, the results of which will not be publicly reported on HH Compare; and (2) the HHAs must conduct a dry run for at least one of the months in the third quarter of 2010, and continuously collect HHCAHPS data every month beginning in October 2010. The specific deadlines for the dry run in the third quarter of 2010, and the deadline for the fourth quarter are stated in the Final Rule.

Finally, the Final Rule states that there will be exemptions for newly Medicare-certified HHAs, and also for HHAs with less than 60 eligible patients in an annual period that is defined in the rule. HHAs must provide CMS with patient counts from April 1, 2009 through March 31, 2010 (if fewer than 60) by June 16, 2010 to be exempt from the 2012 APU reporting requirements.

For more information on health law issues, please visit www.wachler.com or contact a Wachler & Associates attorney at 248-544-0888.