ASC’s and HOPD’s across the country have been quarreling with it for well over a year and a half now as CMS continues to see-saw. It seems like every other day we are getting calls from facility representatives wanting to know if they “have to” participate yet. Quotes are necessary, of course, because the guidelines for all CMS surveys can be a lot to grasp for new facilities or even just facilities new to CAHPS. In the case of OAS CAHPS, that includes just about every freestanding Ambulatory Surgery Center in the country.


For those facilities who have managed to fly above the news cycle surrounding OAS CAHPS, here’s your 1-minute abridged version: the acronym itself stands for the Outpatient Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems. The OAS part is new as of 2016 but CAHPS has been around for years in the form of HCAHPS for Hospitals, HHCAHPS for Home Health Agencies, and many others. Don’t be intimidated by the name though, that lengthy acronym is just government speak for a patient survey. When it comes to CMS’s approach to implementation, there’s been one key difference between OAS CAHPS and the others – the (now twice) delayed rollout of “mandatory” participation. When looking for an explanation for why this happened, it’s difficult to find much more than what is available on the website:

“In this Proposed Rule, CMS proposes to continue voluntary participation in the Outpatient and Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS) Survey Based Measures…until further action in future rulemaking”


In particular, this decision has put ASC’s in a vulnerable position. Most Hospitals began adopting the survey early on, having already gained familiarity with HCAHPS and what to expect from CMS. They had the reporting down, the quality improvement process down, coordinating with survey vendors and so on. The announcement of OAS CAHPS was essentially just another day at the office and another check to write for many of them. On the other hand, ASC’s were more or less blindsided with the following decision:

1.Optionally begin participation now (this was in 2016) to help get your feet wet but you’ll have to contract with an approved vendor.


2. Delay your participation and save money, but at the risk of falling behind your competitors and other early adopters.

Though CMS is generally tight-lipped about the actual reasons behind the delay

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, it’s not a far reach to suggest that they received a great deal of pushback from ASC’s and their organizations for the above-stated reasons. After all, is it really fair to hold a freestanding facility to the same standards as a resource-rich Hospital which is already experienced in CAHPS reporting? For the sake of the surgery centers’ (and hospitals’, for that matter) dollars, we can cross our fingers and hope that CMS decides to walk back the regulations entirely. However, you could argue that the smart move would be to make this the opening statement for a “hope for the best and plan for the worst” scenario.


By now, there’s sure to be at least a handful of ASC administrators who have been given a rightful pat on the back for saving a year and a half worth of survey vendor fees. Indeed, it has so far held that CMS will not be rolling out pay-for-reporting standards for at least another 12 months. However, in defining a worst case scenario, you have to weigh the cost-benefit decision against the cost-cost decision by asking: What would happen if CMS announced pay-for-reporting standards and our facility is one of the last ones on board?” This is where the reality of being penalized starts to become a concern.

Now that the first batch of public data has been made available, you can bet that OAS participants nationwide are gauging their performance against every one of the early adopters to see how they fare. If performance is below par

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, they’ve bought themselves valuable time to carry out an improvement plan:

  1. Analyze performance relative to peers
  2. Investigate sources of poor performance
  3. Develop a Quality Improvement Plan
  4. Calculate the Cost of Improvement Initiatives
  5. Budget Improvement Initiatives
  6. Carry out the QI Plan
  7. Re-evaluate scores when data is next released


 Cost will vary from one vendor to another and there is no single solution that is right for everyone. Our friends over at Outpatient Surgery Magazine suggest OAS CAHPS survey vendors will charge surgical centers and hospital outpatient departments a reported $10 to $25 per completed survey.

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, that’s a pretty broad range. One item to bear in mind when it comes to the cost disparity is that most vendors, including Arbor, offer “add-on” services to help facilities who are aiming for more than just a compliance package. The other variable that has quite a bit to do with cost is the survey mode. For almost all CAHPS surveys, the only allowable survey modes are Phone and Mail. Yes, this means that CMS will not accept web-based surveys or those completed via email. Typically

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, phone surveys are more expensive due to the fact that approved survey vendors must utilize call centers based in the United States and who employ telephone interviewers.

Still having trouble deciding which mode is best for you? The same article referenced above had the following to say:

…working with a vendor that relies exclusively on paper surveys creates a potential issue. Will patients throw them away and not respond, preventing your facility from collecting the 300 completed surveys a year that CMS requires? If you’re already sending out your own paper patient satisfaction surveys…it might make sense to partner with a vendor that conducts phone call surveys, so your patients dont get confused when 2 envelopes show up in the mail.

So there you have it. The good, the bad and the ugly of OAS CAHPS surveying really comes down to, ironically, your perspective. Each facility is faced with the same decision and has to figure out the type of business mentality they are going to have for this project. Will you be the forward-thinking, progressive center that stays on top of the regulations or will you be the cautiously optimistic, quick-on-your-feet center that can adapt at a moment’s notice? In either case, it doesn’t cost a thing to speak with vendors now to get a better idea of what to expect. You may even be able to narrow your field of prospects for when decision time comes. Interested in including Arbor on that list? Feel free to check with us today and find out how we can help.