ENA Supports Proposed Changes to Medicare Patient Survey

September 6, 2016

The Honorable Andrew M. Slavitt
Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building,
200 Independence Avenue, S.W.,
Washington, DC 20201

Submitted electronically via www.regulations.gov

RE: Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Organ Procurement Organization Reporting and Communication; Transplant Outcome Measures and Documentation Requirements; Electronic Health Record (EHR) Incentive Programs; Payment to Certain Off-Campus Outpatient Departments of a Provider; Hospital Value-Based Purchasing (VBP) Program (CMS-1656-P)

Dear Acting Administrator Slavitt,

On behalf of the Emergency Nurses Association (ENA) and our 42,000 members, I am writing to provide comments and recommendations related to the Hospital Consumer Assessment of Healthcare Providers and System (HCAHPS) survey as you finalize payment and other policies for CY 2017 under the Hospital Outpatient Prospective Payment System (OPPS).

In the proposed rule, the Centers for Medicare and Medicaid Services (CMS) has indicated that it will remove the HCAHPS pain management dimension for the purposes of the Hospital VBP Program beginning in fiscal year 2018. Specifically, CMS is proposing to remove the HCAHPS pain management dimension (which consists of three questions) in the Patient- and Caregiver-Centered Experience of Care/Care Coordination domain. The three survey questions used to construct this dimension are as follows:
          12. During this hospital stay, did you need medicine for pain?
          No (If No, Go to Question 15)

          13. During this hospital stay, how often was your pain well controlled?

          14. During this hospital stay, how often did the hospital staff do everything
          they could to help you with your pain?

Commenters have raised concerns about these questions, noting confusion about their intent, as well as the public health implications related to the ongoing prescription opioid overdose epidemic. In a letter dated January 8, 2016, ENA raised concerns about the same and similar questions that were included in a related survey, the Emergency Department Patient Experience of Care (EDPEC) survey, planned for use in emergency departments nationwide.

ENA supports CMS’s proposed removal of the questions from the Hospital VBP Program and we encourage CMS to incorporate these changes in the final OPPS rule. Further, we look forward to reviewing the results of CMS’s ongoing research with respect to the HCAHPS survey questions and any modifications that are made to the pain management dimension questions.

Finally, we appreciate the ongoing dialogue with CMS staff related to the EDPEC survey and consideration of our concerns as this survey is finalized. It is our hope that the proposed changes to the pain management dimension of the HCAHPS survey be translated into similar adjustments to the EDPEC survey as a separate, but related, instrument. We encourage CMS to expedite the EDPEC survey review process so that it can be forwarded for CAHPS accreditation.

Thank you for considering our views with respect to the HCAHPS survey and we look forward to working closely with CMS on this important issue. Should you have any questions or to set up a time to speak, contact Richard Mereu, ENA’s Chief Government Relations Officer, at 202-741-9373.

Kathleen E. Carlson, MSN, RN, CN, FAEN
2016 ENA President

About the Emergency Nurses Association

The Emergency Nurses Association (ENA) is the premier professional nursing association dedicated to defining the future of emergency nursing through advocacy, education, research, innovation, and leadership. Founded in 1970, ENA has proven to be an indispensable resource to the global emergency nursing community. With more than 43,000 members worldwide, ENA advocates for patient safety, develops industry-leading practice standards and guidelines, and guides emergency healthcare public policy. ENA members have expertise in triage, patient care, disaster preparedness, and all aspects of emergency care. Additional information is available at www.ena.org.

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