Quick Look at HHCAHPS in the Medicare Program Home Health Final Rule
folder_openInformation for Home Health Agenciescalendar_todayPosted November 11, 2009

The Final Rule was published in the Federal Register on November 10, 2009 (42 CFR 409, 424, 484 [10 November, 2009]), and the section on Home Health Care CAHPS (HHCAHPS) is found on pages 58099–58104. A link to the Final Rule is provided here: http://edocket.access.gpo.gov/2009/pdf/E9-26503.pdf.

The Centers for Medicare & Medicaid Services (CMS) strongly recommends that the rule be read in its entirety by all Medicare-certified home health agencies. For HHCAHPS, CMS adopted three changes to the previously proposed provisions:

• The first change is the delay of 1 year in the HHCAHPS linkage to the annual payment update from CY 2011 to CY 2012. This delay means that home health agencies will need to conduct a dry run in July, August, and/or September 2010, and then continuously collect survey data beginning in the fourth quarter 2010 and moving forward.
• The second change concerns the patients eligible for the survey: only patients covered by Medicare and/and/or Medicaid will be eligible to be included in the HHCAHPS survey.
• The third change is that V codes may be submitted for diagnoses if numeric ICD-9 codes are unavailable in the patients’ records.

CMS is delaying the linkage of HHCAHPS to the annual payment update until CY 2012 to allow home health agencies (HHAs) to first fully implement OASIS-C before being required to implement the HHCAHPS survey for payment considerations. As such, agencies will be required to conduct a dry run for at least 1 month in third quarter CY 2010, and to begin data collection on an ongoing basis in October 2010. The dry run can be for any month during third quarter 2010 and can be for 1, 2, or 3 months.

With this change, agencies will be required to submit dry run data from the third quarter of CY 2010 to the Home Health CAHPS Data Center by 11:59 p.m. Eastern Standard Time on January 21, 2011. Similarly, agencies will be required to submit data for the fourth quarter of CY 2010 to the Home Health CAHPS Data Center by 11:59 p.m. Eastern Standard Time on April 21, 2011. Dry run survey results will not be publicly reported; however, survey results from the fourth quarter of CY 2010 will be publicly reported.

CMS considered the wide variation in the size of Medicare-certified home health agencies and initially proposed that the requirement to collect HHCAHPS survey data be waived for agencies that serve fewer than 60 eligible patients annually. CMS kept this provision in the Final Rule but adjusted the dates to report patient counts because the linkage to the APU was delayed. CMS states in the Final Rule that by June 16, 2010, home health agencies need to provide CMS with patient counts for the period of April 1, 2009 through March 31, 2010. This requirement pertains only to Medicare-certified HHAs with fewer than 60 eligible, unduplicated Medicare or Medicaid patients for that time period. Such home health agencies would be exempt from conducting the HHCAHPS Survey for the annual payment update in CY 2012. Home health agencies that have fewer than 60 eligible, unduplicated Medicare and/or Medicaid patients would be exempt from data collection from third quarter CY 2010 through second quarter CY 2011.

To determine whether an agency can be exempted from conducting HHCAHPS, home health agencies should count patients whose skilled care visits were paid for by either Medicare or Medicaid and who:

• were at least 18 years of age at time of service and their home health care;
• received at least two skilled care visits from agency personnel from April 1, 2009 through March 31, 2010;
• were not discharged to hospice care during the time of service;
• did not have “maternity” as the primary reason for receiving home health care; and
• did not request a “no publicity status.”

Those agencies that have fewer than 60 patients who meet the above criteria will be exempted from conducting the HHCAHPS. More information about how small agencies can apply for an exemption from participating in HHCAHPS will be posted on https://homehealthcahps.org in February 2010.

Please contact the HHCAHPS Coordination Team via e-mail at hhcahps@rti.org with any questions.