The Centers for Medicare & Medicaid Services (CMS) and the OAS CAHPS Survey Coordination Team would like to share updated guidance to determining eligibility for the OAS CAHPS Survey within hospitals. Medicare-certified hospitals are eligible to participate in the OAS CAHPS survey if they meet all of the following criteria:

• The hospital has one or more hospital outpatient surgery departments or other specialized departments that perform outpatient procedures and surgeries.
• These departments perform procedures that are within the OAS CAHPS-eligible range of CPT-4¹ Codes for Surgery (i.e. CPT codes between 10021- 69990) or one of the following G-codes: G0104, G0105, G0121 or G0260.
• These departments bill under the Outpatient Payment Prospective System (OPPS).
• The OAS CAHPS-eligible procedures are not performed in an office setting (doctor’s office) or the emergency department.

These criteria are intended to ensure that OAS CAHPS surgeries and procedures are not overlapping with any other CAHPS Surveys such as Hospital CAHPS, Clinician & Group CAHPS or Emergency Department CAHPS.

UPDATE: One criterion was removed.

• The OAS CAHPS-eligible procedures performed within the department are performed by a doctor (not a technician).

In addition to the eligibility criteria listed above for the facility itself, hospitals should also take into consideration whether there are certain procedures that fall within the Codes for Surgery (10021-69990) that could be considered inappropriate for the OAS CAHPS Survey. As part of this consideration, hospitals should consider whether procedures performed by physician assistants, nurse practitioners or technicians would be appropriate for the OAS CAHPS Survey. Some OAS CAHPS questions refer to the doctor. If a patient saw a different provider for example, a technician, physician assistant or nurse practitioner for a procedure, some of the questions might be difficult for patients to answer. Also, some procedures listed in the range Codes for Surgery include pre-operative or post-operative follow-up tests. These types of procedures could be considered minor enough that some of the OAS CAHPS questions about advance preparations and recovery might not seem appropriate to the patients. Hospitals should work with their OAS CAHPS vendors to identify procedures that are either minor in nature or were not performed by a doctor and submit an Exceptions Request Form to determine if specific CPT codes should be excluded for the OAS CAHPS Survey. CMS will review all such requests.

Additionally, units that meet the above criteria that are within critical access hospitals (CAHs) are also eligible to participate in the OAS CAHPS Survey even though CAHs do not bill under OPPS.

Note that this new guidance supersedes the previous definition of eligible hospital outpatient departments (HOPDs), as eligible HOPDs are not the only units in the hospital where OAS CAHPS-eligible procedures or surgeries are performed. Also eligible departments do not have to have outpatient surgery as their primary focus. The clarification provided in this announcement will be included in the next version of the OAS CAHPS Survey Protocols and Guidance Manual.

Please contact the OAS CAHPS Survey Coordination Team via e-mail at oascahps@rti.org or call toll-free (866) 590-7468 if you have any questions about determining eligibility within hospitals.