Hospice Groups to CMS: Don’t Rush CAHPS Changes

Hospice industry organizations have voiced support for proposed updates to the Consumer Assessment of Healthcare Providers and Systems (CAHPS) surveys, but raised questions on the implementation timeline.

The U.S. Centers for Medicare & Medicaid Services (CMS) included the updates in its proposed hospice payment rule for 2025. If finalized as written, the changes would take effect in January 2025. Performance on these surveys is crucial as more payers and consumers use public quality data to choose a hospice. It can also influence whether a hospice provider ends in CMS’ recently implemented Special Focus Program.

One key concern about the timeline is the need for vendors to develop updated electronic medical record (EMR) systems as well as methods of collecting the data, according to Katy Barnett, director of home care and hospice operations for LeadingAge.


“We ask CMS to push that off, because the reality is — getting EMRs and getting the survey vendors up to speed — they’re gonna have to build out a completely new process. They are going to have to build out a process for collecting emails and putting that in the EMR to send to the right vendors,” Barnett told Hospice News. “If the final rule drops in August, there’s only four months to implement this huge change. We support it, but we need more time to make sure that it actually works.”

The proposed changes include:

  • The addition of a web-mail mode (email invitation to a web survey, with mail follow-up to non-responders)
  • A shortened and simplified survey
  • Modifications to survey administration protocols to include a prenotification letter and extended field period
  • The addition of a new, two-item Care Preferences measure
  • Revisions to the existing Hospice Team Communication measure and the existing Getting Hospice Care Training measure
  • The removal of three nursing home items and additional survey items impacted by other proposed changes in this rule.

Behind the changes is a desire to increase response rates, which have been declining. Between the 2021 and 2023 reporting period, those rates reached only 29%, according to data cited in comments on the rule by the National Hospice and Palliative Care Organization (NHPCO). 


“These changes are long overdue, and shortening the survey, simplifying survey language, and expanding survey delivery methods to include a web-mail mode option will collectively help address historically low response rates,” NHPCO indicated in its comments. “Although we support these proposals, we are concerned the January 2025 implementation date will not provide sufficient time both for hospices, particularly smaller and resource-limited providers.”

The industry groups have requested that CMS push back the implementation date to Jan. 1, 2026 at the earliest.

Other concerns about the CAHPS survey include the lack of a risk adjustment for socioeconomic factors that could affect underserved populations. This can result in an inaccurate assessment of hospice performance, according to the industry organizations. 

“To address this, we recommend CMS enhance the CAHPS survey to include a culturally  competent approach that accurately captures diverse patient populations. Accordingly, we recommend CMS utilize available race and ethnicity data in adjusting the Hospice CAHPS case,” NHPCO said in its comments. “… Given the scope and breadth of proposed changes, we strongly recommend that CMS complete a  thorough analysis of proposed CAHPS changes, including the mode of delivery and its associated impact on the hospice SFP.”

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