Tip: Make your training sessions fun-size rather than king-size in runup to new assessment tool. Every day counts, with less than 100 days to go until OASIS-E implementation. Kicking OASIS-E preparations into high gear — or starting them if you haven’t already — is crucial to success with the new assessment tool. And OASIS-E success will impact Value-Based Purchasing, Care Compare outcomes, and more. “It’s definitely time to start if you have not already,” urges Angela Huff with FORVIS. Smooth OASIS-E implementation contributes to VBP results. “You can’t trip at the start line of your [VBP] performance year, because it will be really hard to regain ground in this new world of competition in the large and small agency cohorts,” Huff warns. In the race to OASIS-E and VBP implementation, “you have to ‘get off the line’ smoothly and quickly,” she exhorts. Beginning now is key for comprehensive understanding by the start date. “Taking bite-size pieces and incorporating at a slower pace will create an easier transition than having multiple new items and processes to implement on Jan. 1,” advises Karen Tibbs with consulting firm McBee. “Fourth quarter is time to be prepping your clinicians on the correct way to complete the new assessment items — particularly the BIMS and the CAM,” recommends J’non Griffin with SimiTree Healthcare Consulting. (The multi-item Brief Interview for Mental Status and Confusion Assessment Method are new to this OASIS update.) “I recommend introducing some of the new concepts during October, such as the focus on Social Determinants of Health and the expanded mental health assessments that clinicians will see in OASIS-E,” Noyce says. Using the next three months to “learn and practice the assessment steps for the new cognitive items, BIMS and CAM … will prepare clinicians to perform these efficiently and accurately once they are required,” Noyce counsels.
On the other hand: “I think it is still too early” to teach OASIS-E specifics, “especially since the final version isn’t out yet,” shares Arlynn Hansell, also with SimiTree. “I would look at early to mid-November.” HHAs can use October to focus on OASIS accuracy and problems with existing items that will be crucial to VBP and outcomes, suggests Cindy Krafft with Kornetti & Krafft Health Care Solutions. “Brand new items should be closer to Jan. 1, 2023,” Krafft judges. Whether you start OASIS-E training immediately or in several weeks, there’s still lots to fit in between now and Jan. 1. “It will be a wild ride for home health agencies in the next six months,” Griffin says. Heed this advice from the OASIS experts to survive and thrive under the updated tool: 1. Check EMR. Before you get heavily into training staff on specific items, you need some crucial info from your electronic medical records vendor. “Depending on how the EMR lays things out,” the most difficult part of OASIS-E “might be finding where items are,” Hansell warns. Griffin recommends that as a first step, “the agency needs to find out (if they haven’t already) how the EMR will be setting up the OASIS in the system. Will the EMR put the new OASIS in the new format or will they simply try to add items in to their existing format?” she asks. “If the new format is used, clinicians will need to be oriented to where the items are, as the new format will take some time to become familiar with where items are located,” she explains. Time is of the essence. HHAs should “check with their EMR vendor to be sure the tools that will be available for documenting OASIS-E will be in place in time for the agency to preview how the changes will look,” Noyce advises. Plus: Agencies “should ask any OASIS scrubber vendors what new logic will be in place to help with documentation accuracy with OASIS-E implementation,” Noyce adds. 2. Set up your training schedule — option 1. “The OASIS-E is made up of 25 percent of new items, so certainly focus on those,” Huff recommends. “But don’t miss the opportunity to continue to focus on the items that impact PDGM and VBP that are part of the 75 percent that are unchanged,” she urges. “It’s … important to review OASIS documentation conventions in case anyone needs a refresher and so that everyone is on the same page,” Noyce maintains. “Current challenges with OASIS accuracy … need to be addressed ASAP as they have PDGM and outcome implications — including HHVBP,” Krafft says. For example: “The No. 1 issue I find over and over is the back and forth between clinicians and reviewers about the assessment of function,” Krafft shares. Under OASIS-E, “the M1800s and GGs are all going to stay the same,” she notes. That means the functional assessment issue “needs to be put to bed ASAP, considering how much time and dime is spent on corrections,” Krafft tells AAPC. HHAs that don’t have their OASIS accuracy down cold will want to spend the early part of the fourth quarter focusing on eliminating such OASIS errors, then move on to the new OASIS-E items closer to implementation. 3. Set up your training schedule — option 2. Agencies that have already drilled clinicians on OASIS accuracy will be ready to move into OASIS-E specifics right away, experts suggest. Starting with the BIMS, CAM, and PHQ-2 and 9 assessments should top the list. Then, in “November and December, offer ample time to teach the entire tool in digestible pieces,” Noyce advises. Under this schedule, staff will “have time get their minds around what will be different and what will remain the same,” she says. “Some of the additions are straightforward and should not take a lot of time to train, but other items definitely require understanding the guidance,” Huff cautions. “Incorporating that guidance and educating your clinicians on where they can quickly find and reference that resource should be a primary focus,” she says. “It’s critical that clinicians are very competent in completing this tool, and they can’t do that if they don’t fully understand the intent of the items,” she points out. Important: As you train ahead of time, “the key is to clearly identify what is still in effect through the end of the year and what will be new on Jan. 1, 2023,” Noyce underscores. 4. Create new tools. There are lots of new details for staff to remember under OASIS-E, and they’ll need some help. “Agencies will need to develop tools to assist their clinicians with the new items,” Griffin expects. And the tools shouldn’t stop with learning the newly updated instrument. “Develop action items for clinicians to use when the new cognitive and mood assessments indicate needed follow-up for the potential presence of conditions,” Tibbs encourages. And providers should “create a community resource list to make available to clinicians to utilize for patients that have challenges with health equity,” Tibbs offers. “For example, develop a list of resources for transportation to and from provider appointments in your service area,” she suggests. 5. Keep it up. A few bursts of intensive training won’t work as well as a continuous, manageable stream. After introducing items, HHAs should provide “weekly training on the new items with practice scenarios,” Griffin advises. “It will be important for clinicians to remember what is included and excluded for each item separately from the others,” she highlights. For example: “Continuous oxygen for M1400 is different than continuous oxygen in the new O section,” Griffin flags. 6. Prioritize social Determinants of Health. While the cognitive and mood assessments will top most agencies’ training topic list, SDoHs won’t be far behind. “Train clinicians on the new SDoH items,” Tibbs urges. “These have specific instructions for who can answer and what order sources are utilized for responses,” she highlights. “SDoH are important to consider to mitigate obstacles for providing quality care and meeting outcomes,” she tells AAPC. Providers should be “familiarizing themselves with community resources, such as transportation, interpreters, etc.,” Griffin recommends. “Some of these things should already be in place,” she notes. “I can also foresee social workers being utilized more,” she adds. 7. Line up your other hot topics. “Ensure clinicians are accurately performing medication reconciliation each visit,” Tibbs advises. And “review current transfer policies,” Tibbs adds. “Revise to match the new Transfer of Health process to successfully meet the new measure.” 8. Use your judgment. “As we get into it, there will be several questions that come up that weren’t addressed in the original guidance,” Griffin notes. “As for now, many items will be ‘use your clinical judgement,’” she says. This can be a plus, giving HHAs more flexibility. “There are many circumstances that are not specifically addressed in the guidance,” Tibbs acknowledges. “Take advantage of the ability to use clinical judgment,” she urges. 9. Focus on point of care documentation. It’s time to get forceful about assessing clinicians documenting in the home. “Many of the new items require the question be read to the patient exactly as written,” Krafft cautions. “For clinicians that still won’t or don’t integrate the use of the computer into the visit — or leave it in the car — this is going to be a big issue,” she forecasts. 10. Watch for problems in assessments spanning Jan. 1. Operational and system problems on the Medicare contractor and claims system side are an eventuality that agencies can’t control. But they can minimize problems from their end on certain tricky assessments and claims. “There’s always the chance that an assessment that begins Dec. 31 will be completed on Jan. 1 or later,” Noyce offers. “In cases like that, the clinician completing the SOC/ROC/ Recert OASIS and comprehensive assessment needs to be sure they’re using the correct version of the OASIS to avoid having to document the same thing more than once,” she advises. Note: The 396-page OASIS-E Guidance Manual is at www.cms.gov/files/document/oasis-e-guidance-manual51622.pdf.