CMS Reminds CHHAs: Only Two Scenarios for HHCAHPS Survey Exemptions 

Situation Report | March 1, 2021

The U.S. Centers for Medicare and Medicaid Services (CMS) recently reminded Certified Home Health Agencies (CHHAs) that they must participate every month in the Home Health Consumer Assessment Healthcare Provider Survey (CAHPS) to obtain the full Annual Payment Update (APU) or market basket update.   

There are only two scenarios where a CHHA can be exempted from participation. Otherwise, they are subject to the 2 percent APU penalty. The exemption scenarios are: 

  • If a CHHA served 59 or fewer survey-eligible unduplicated patients from April 1, 2019 to March 31, 2020.
  • If a home health agency received Medicare certification from CMS after April 1, 2020, in which case the agency is considered too new to participate in the upcoming APU. This is a one-time exemption only, and CHHAs do not need to apply for it.

CHHAs meeting the criteria for having served fewer than 59 survey-eligible unduplicated patients can submit a participation exemption request for the 2022 annual payment update. Agencies must apply for the exemption annually. The form for doing so here is due by March 31, 2021.