OOSS Critical of New Quality Measure and Patient Experience Survey

ASC Reporting on Cataract Patient Visits to Hospital

On December 9, OOSS – with ASCRS, AAO, and ASRS signing on — filed comments strenuously urging the Measures Application Partnership (MAP) – a joint venture convened by the National Quality Forum (NQF) to provide input to CMS on selecting performance measures for public reporting and performance-based payment – to reject a cataract outcomes measure under consideration.  The MAP is comprised of 110 members from hospitals, health plans, clinicians, business, labor, consumers, and accreditation and state agencies – but apparently receives little, if any, input from the ophthalmology and ASC communities.


The MAP group is considering a mandate that facilities measure “the combined rate of unplanned admissions, emergency department visits, and observation stays among Medicare FFS beneficiaries within 7 days after receiving a cataract surgery at an ambulatory surgery center or other outpatient facility.” In vehemently opposing the measure, we argued that ASCs, lacking legal and practical access to hospital records, are incapable of reporting such data.  The ophthalmology community recommended that the MAP defer action on the measure until it has been more thoroughly vetted and tested.

Our comments can be reviewed at: http://gallery.mailchimp.com/7c22b09a4cf43906a0ce9690e/files/MAP_Comments_by_AAO_ASCRS_ASRS_OOSS_2013.pdf


Medicare Patient Experience Survey

Earlier this year, CMS announced its intention to design, develop, and implement a survey regarding patient experiences, including satisfaction and outcomes, with respect to surgical services provided by ASCs and hospital outpatient departments (HOPD).  The ophthalmology community submitted comments to the agency recommending that the financial and administrative burdens associated with administering the survey be as modest as possible and that the survey incorporate only a limited number of topics and questions.

The proposed survey instrument developed by CMS and published two months ago is unacceptable in a number of respects.  Of greatest consequence, the survey includes 47 items.  In our comments submitted on December 3 – filed along with the AAO, ASCRS, and ASRS – we stated that  “we are disappointed  the agency’s product and believe that, as currently drafted, very few patients would opt to complete the survey. . . Our patients’ encounters in the facility are brief and experience strongly suggests that they are unwilling to invest more than a few minutes responding to surveys about their ASC experience.”  OOSS will continue to closely monitor CMS’ progress and vigorously urge the agency to adopt our recommendations, thereby ensuring that a manageable survey is available to our patients that will generate meaningful data from which beneficiaries can compare the care provided by ASCs and HOPDs.


Our comments can be reviewed at: http://gallery.mailchimp.com/7c22b09a4cf43906a0ce9690e/files/AAO_ASCRS_ASRS_OOSS_Comments_on_Patient_Experience_Survey.pdf


The CMS draft patient experience survey can be reviewed at: http://gallery.mailchimp.com/7c22b09a4cf43906a0ce9690e/files/CMS_Patient_Experience_Survey.pdf


OOSS will keep you abreast of further developments.  Should you have any questions regarding the rule, please contact our Washington Counsel, Michael Romansky, at mromansky@OOSS.org.

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