Home Health & Hospice Week

The final rate update comes with many changes, but there's one in particular that's guaranteed to make your life a little bit easier. After a bevy of comments on its proposed requirement to force all agencies to use the Home Health Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey, the Centers for Medicare & Medicaid Services has decided to delay portions of the requirement for a full year.

Good news: The CAHPS survey won't be linked to the quality reporting requirements for the annual payment update for another six months so that you can focus on transitioning to OASIS C. And the survey won't be tied to the annual payment update until 2012, according to the Home Health Prospective Payment System final rate update, released on Oct. 30 and slated for publication in the Nov. 10 Federal Register.

In the time between now and then, CMS plans to make some crucial changes and additions to the survey. Here's what's topping their list:

• Create a control group. Many commenters on the final rate update expressed concern that the CAHPS survey doesn't adjust to account for variation in quality scores that aren't related to an agency's compliance program or behavior. Where most agencies have developed a method for ranking and weighting patient feedback, the CAHPS survey seemed to weight all responses the same -- regardless of demographic or insurance information.

Response: CMS agreed with these commenters and pointed out that it sees "the prevention of spurious variables on the data" as "essential" to successfully incorporating the survey. To alleviate concerns and create a control group that doesn't require extensive adjustments, CMS has decided to include only Medicare and Medicaid patients in the survey.

The agency will also adjust results to account for patient mix, which it describes as "characteristics that are beyond home health agencies' control." CMS has already identified several patient mix characteristics, including overall health status, diagnosis information, age, education, managed care indicator, and whether the patient lives alone. CMS will re-evaluate these characteristics each reporting period.

• Modify specifications to include V

codes. The proposed rule instructed agencies to use ICD-9 codes to report patient mix, but more than 40 percent of agencies use V codes to indicate patients' primary diagnoses -- even though they don't accurately reflect medical conditions, commenters noted.

Response: CMS wants agencies to use ICD-9 codes in place of V codes, but it won't require you to follow that rule. The agency will modify the specification to allow agencies to submit V codes -- but only when no accurate ICD-9 code is available.

However, CMS encourages all agencies to switch over to ICD-9 codes, which allows you to better distinguish patients and their attitudes about health care. For instance, say two patients are coded with one of the V57 rehabilitation codes. One had knee surgery and the other had a stroke. These patients will have different perspectives and opinions about their health care, but the V code doesn't alert CMS to a difference in severity or condition.

• Develop oversight criteria. An overwhelming number of commenters wanted to know how CMS planned to ensure that surveyors -- and the survey outcomes -- are on the up-and-up.

Response: You must depend on a thirdparty vendor to complete your survey, but you don't have to trust that your vendor is following the rules. CMS will conduct oversight activities for all CAHPS vendors, the final update stated.

Those activities will include monitoring information about patient eligibility and random sampling. The agency will then work with the vendor to correct any mistakes.

• Translate the survey into more languages.

Most home health patients speak either English or Spanish, but there are many who understand neither language. Many commenters asked CMS if they could translate the survey into the languages that their patients can understand.

Response: CMS understands that agencies need their patients to understand the survey, but that doesn't mean you can translate it yourself. CMS wants to keep translation in-house to avoid any word or meaning changes that could affect the survey's comparability on a national basis.

The Survey Coordination Team is currently translating the survey into Chinese.

Important: Although the survey isn't linked to the annual payment update for another two years,  you still have some compliance work to do.

You are required to perform your first CAHPS survey dry run in at least one of the months in the third quarter of 2010. Agencies must also begin ongoing data collection in October 2010, the final update says.

Resources: You can read the final rate update at http://federalregister.gov/OFRUpload/OFRData/2009-26503_PI.pdf. Access CAHPS survey data at www.homehealthcahps.org.