Must every hospice participate in the CAHPS hospice survey?

What is the CAHPS hospice survey?

The CAHPS hospice survey is administered to eligible caregivers after a patient’s death to measure the quality of care and communication provided by the hospice. A hospice agency must participate in the CAHPS Hospice Survey to be eligible for its full annual payment update (APU). Failure to participate will result in a 2% reduction in APU. For example, compliance with the 2022 CAHPS Hospice Survey affects fiscal year 2024 APU.

Are all hospices required to administer the CAHPS hospice survey?

All Medicare certified hospice agencies should participate in the CAHPS hospice survey with two exceptions:

• Size Exemption: The exemption is based upon the number of decedents the hospice served in the prior calendar year. If the hospice served fewer than 50 survey eligible decedents or caregivers in the prior calendar year, the hospice is exempt from the CAHPS hospice survey
• Age Exemption: The exemption for age of hospice is based upon the date that the hospice received its CCN. The hospice is exempt for the remainder of the calendar year in which it receives its CCN.

CMS identifies hospices that are exempt due to age. A hospice agency is not required to file a form to request Age Exemption.

CMS does not identify hospices that are exempt for due to size. A hospice agency must apply for a Size Exemption and must apply for the Size Exemption each year that it wishes to be eligible for this exemption.

How does a hospice apply for a Size Exemption?

The hospice must complete a Participation Exemption for Size Form. The form, deadlines for submission, and details for completion can be found here.  

The form requires not only a count of total patients who died while in hospice care, but certain details about these patients to determine the count of survey eligible patients and caregivers. For example, the hospice will need to submit counts of the number of patients

• who were under 18 when they died
• where there is no caregiver on record
• who died within 48 hours of final admission to hospice care

and several other categories. Care must be taken that patients are only counted in one of the categories even if they fall into multiple categories, to eliminate double counting.

What happens once a hospice submits a size exemption form?

Immediately upon submission of the form, the CAHPS Hospice Survey Project team will confirm receipt of the form. This confirmation, however, is not equivalent to Size Exemption approval. CMS will review the data to determine if the exemption is met. If CMS determines that the exemption is not met, the hospice is responsible for survey administration. Hospice agencies must accurately complete the Participation Exemption for Size Form so that they are not faced with a rejection by CMS. If the Size Exemption is not met and the hospice agency has missed administering and submitting surveys, the hospice agency will face an APU reduction.

Where can you find more information?

• US Dept of Health and Human Services: CAHPS Hospice Survey – Description of survey, participation requirements, and key dates:  HHS – CAHPS Survey
• What is the CAHPS survey?
• Selecting a CAHPS Hospice Survey Vendor