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Quality Assurance Guidelines CAHPS® Hospital Survey - HCAHPS

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March 2011<br />

<strong>Survey</strong> Management<br />

receipt and handling of returned surveys, through data entry, validation and edit<br />

checking) on an ongoing basis, and verify that staff and subcontractors are compliant<br />

with HIPAA regulations<br />

‣ provide feedback on performance of all staff and subcontractors, through regular<br />

assessments, with special emphasis placed on detection and correction of identified<br />

performance problems<br />

The <strong>HCAHPS</strong> Project Team will conduct on-site visits to hospitals/survey vendors to review<br />

hospitals’/survey vendors’ operations, monitoring and quality oversight practices. As noted<br />

earlier, if a survey vendor is non-compliant with program requirements for any of their<br />

contracted hospitals, the hospital’s data may not be publicly reported.<br />

Safeguarding Patient Confidentiality<br />

<strong>Hospital</strong>s/<strong>Survey</strong> vendors must take the following actions to further protect the confidentiality of<br />

patients:<br />

‣ Prevent unauthorized access to confidential electronic and hard copy information by<br />

restricting physical access to confidential data (use locks or password-protected entry<br />

systems on rooms, file cabinets and areas where confidential data are stored)<br />

‣ Develop <strong>HCAHPS</strong> or survey specific confidentiality agreements and obtain signatures<br />

from all personnel with access to survey information, including staff and all<br />

subcontractors involved in survey data collection<br />

‣ Confirm that staff and subcontractors are compliant with HIPAA regulations in regards to<br />

protected health information (PHI)<br />

‣ Establish protocols for secure file transmission. Emailing of PHI via unsecure email is<br />

prohibited.<br />

‣ Establish protocols for identifying security breaches and instituting corrective actions<br />

‣ Establish protocols for identifying patients who are excluded from the <strong>HCAHPS</strong> survey.<br />

For a list of exclusions, please refer to the Sampling Protocol section of this <strong>Quality</strong><br />

<strong>Assurance</strong> <strong>Guidelines</strong> V6.0 manual. Excluded patients are removed from the eligible<br />

patient list by the hospital/survey vendor before the <strong>HCAHPS</strong> sample is drawn. Patients<br />

found to be ineligible after sampling must not be replaced in the sample.<br />

‣ Store returned mail questionnaires in a secure and environmentally safe location<br />

Note: It is strongly recommended that the method used by contracted hospitals to transmit<br />

information (e.g., patient discharge files, etc.) to the hospital/survey vendor be reviewed by the<br />

hospitals’ HIPAA/privacy officer to confirm compliance with HIPAA regulations. Any materials<br />

(e.g., QAP, questionnaires, cover letters, tracking forms, etc.) submitted by the hospital/survey<br />

vendor to the <strong>HCAHPS</strong> Project Team must be blank templates and must not contain any patient<br />

PHI.<br />

Data Security<br />

<strong>Hospital</strong>s/<strong>Survey</strong> vendors must securely store patient identifying electronic data and responses to<br />

the survey. <strong>Hospital</strong>s/<strong>Survey</strong> vendors must take the following actions to secure the data:<br />

‣ Use a firewall and/or other mechanisms for preventing unauthorized access to the<br />

electronic files<br />

Centers for Medicare & Medicaid Services 37<br />

<strong>HCAHPS</strong> <strong>Quality</strong> <strong>Assurance</strong> <strong>Guidelines</strong> V6.0

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