Home Health & Hospice Week

From medical review to star ratings to surveys, expect the revised assessment tool to have a big effect.

Don't let OASIS-D's impact on a wide variety of your agency's areas of operation take you by surprise.

The OASIS-D changes "only amplify the new Conditions of Participation and the OASIS one clinician rule change, that more coordination of care will need to happen in home health," believes consultant J'non Griffin, owner of Home Health Solutions in Carbon Hill, Alabama. The changes may mean agencies need to implement "a true care planning meeting/interdisciplinary meeting like they do in a skilled nursing facility within the first five days of admission," she predicts.

Therapist impact: "This also escalates the need for home health therapists to do an evaluation within that five-day period so appropriate coordination of care can truly happen," Griffin tells Eli.

OASIS-D can also give rise to medical review problems, experts warn.

The GG additions are required by the IMPACT Act for cross-setting quality measures and are also used in the SNF and inpatient rehabilitation facility settings. While CMS is adding these sections, it isn't doing away with the other home healthspecific sections it already had in place for many of the same items.

The result: In some cases, the existing home health items and new GG items will ask clinicians to assess the same things differently, and in other cases assess them the same way. Both sets of items hold dangers for home health agencies, experts caution.

Many of the GG items directly conflict with information from the M1800 items, Griffin notes. Why do the differences exist? "While it makes sense for rehab to answer these in an enclosed facility, for nursing (who does the majority of the admissions in home care) it may not make as much sense," Griffin explains.

When an existing item and new GG item ask to assess different things, clinicians may get confused and answer one or the other of them incorrectly, stresses consultant Anita Werner with Fazzi Associates in Northampton, Massachusetts. When medical reviewers take a look at the documentation underlying claims, the discrepancies will lead to denials and lost reimbursement, Werner worries.

Griffin offers the example of GG0130E (Self-Care: Shower/bathe self), which directs clinicians to assess "the ability to bathe self, including washing, rinsing, and drying self (excludes washing of back and hair). Does not include transferring in/out of tub/shower."

In contrast, M1830 (Current ability to wash entire body safely) specifies that it "excludes grooming (washing face, washing hands, and shampooing hair)." However, "in this item, the patient must be able to safely wash their back-which is excluded in GG0130E," Griffin highlights.

Another example: GG0130G (Self-Care: Lower body dressing) tells clinicians to assess "the ability to dress and undress below the waist, including fasteners; does not include footwear."

M1830 (Ability to Dress Lower Body), on the other hand, includes "undergarments, slacks, socks or nylons, shoes."

Again, the "potential for confusion" caused by the footwear differences will lead to errors and "audit red flags," Werner emphasizes.

Bet on it: The fact that for some corresponding GG and M1800 items there should be differences in scoring, and for some there shouldn't, will be an area ripe for OASIS coding inaccuracies, experts warn.

These discrepancies may also lead to problems when surveyors come knocking, industry veterans say.

Another surveyor issue could come from J1800 (Health Conditions: Any Falls Since SOC/ROC) and J1900 (Number of Falls Since SOC/ROC), Griffin predicts. "I think this will ... key surveyors into looking to see if incident reports are being collected on those patients," she says.

Another problem with the items is "if the patient has been on service for several episodes, this may be a long look back period to accurately answer this question," Griffin adds.

Watch For Star Rating Changes

Reimbursement and survey impacts won't be the only ones. The OASIS-D changes will also lead to differences in your outcome scores and star ratings on Home Health Compare, Werner says.

A number of the OASIS items CMS is dropping contribute to risk adjustment, which help determine your outcomes and resulting ratings, Werner notes. And new items won't take their place, at least not for a while, she predicts. That's because the newness of the added OASIS-D items preclude CMS from seeing how they performed historically, so they won't be worked into the risk adjustment formula.

"All they can do is take away things" from the risk adjustment formula, for the time being, Werner says.

The OASIS-D changes won't necessarily be a bad thing, Werner adds. They have the potential to increase your outcomes and star ratings rather than lower them. You'll have to monitor the final OASISD changes and results to know for sure. "You just don't know yet," Werner says.

For HHAs participating in Home Health Value-Based Purchasing, those changes will come with direct reimbursement impacts.

Note: For surefire strategies on how to prepare for OASIS-D, see a future issue of Eli's Home Care Week.