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FFY 2024 HCAHPS Proposed Rule Published

April 24, 2023

In a recent proposed rule, CMS announced several changes for HCAHPS guidelines as a result of observations from the 2021 HCAHPS mode experiment. CMS is currently seeking feedback on the following proposed changes, with the potential for these updates to begin with discharges from January 1st, 2025, forward.

  • Changes to Survey Modes of Data Collection:
    • In response to growing demand for cost-effective internet-based options, CMS is proposing to allow hospitals to use these mixed-modes: Web-Mail, Web-Phone, Web-Mail-Phone. (These same options have been approved for the official OAS CAHPS implementation.) In the mode experiment, these web-first modes yielded improved response rates, a long-standing goal for CMS.
    • Because no hospitals have been using IVR since 2016, CMS is proposing to eliminate this survey mode.
  • Data Collection Period
    • To accommodate the new mixed-mode options, CMS is proposing to increase the data collection period after first contact from 42 to 49 days, to allow adequate time for secondary mode outreach. The 2021 mode experiment also found a statistically significant increase in completed surveys from underrepresented groups during the day 43 to 49 period.
  • Limit on Supplemental HCAHPS Questions
    • National survey response rates have been on the decline and appear to decrease as the number of supplemental items increase. The proposed rule would limit the number of supplemental questions to 12, to prevent survey length from negatively impacting response rates. This limit is consistent with other CAHPS surveys.
  • Spanish Translation for Survey
    • Hospitals will be required to collect a preferred language from every patient and provide this field in the data file.
    • Vendors will be required to administer the Spanish translation of the survey to all Spanish language-preferring patients.

The proposed rule also describes allowing proxy respondents to complete the HCAHPS survey on behalf of a patient. CMS has received ongoing feedback from stakeholders asking for proxies to be permitted, and in the 2021 Mode Experiment, they found that allowing proxies respondents did not impact HCAHPS scores. We expect to have more information on who will be allowed to serve as a proxy and how this will be implemented when the final rule is published.

Additionally, the proposed role is seeking public input on the potential inclusion of patients with a primary psychiatric diagnosis in the HCAHPS survey. CMS is asking if the current survey implementation process might pose any legal barriers or risks when used for inpatients with primary psychiatric diagnoses. They are also evaluating if the potential inclusion in the survey should be limited to a particular sub-group of this population.

The 2021 HCAHPS mode experiment tested new survey content, but no survey changes were included in this proposed rule. Potential survey changes will be submitted to a review and endorsement agency in 2023 and may be proposed in future rulemaking.

We will continue to monitor and communicate any new information released by CMS on the upcoming changes for HCAHPS 2.0. The final rule with additional information and clarification is expected in August, and PRC will post additional updates at that time.

CMS welcomes comments on any of this information, which may be submitted via http://www.regulations.gov by following the instructions under the “submit a comment” tab. If you have more questions about this proposed rule, please reach out to our CAHPS® team at [email protected].