Home Health & Hospice Week

CAHSAH also worried that surveyors would use the item for unwarranted citations. "There is no regulatory requirement for parameters," the trade group said. "Not every patient requires parameters,and, if they are necessary, it can take time to establish them making it unrealistic to establish them at the start of care."

NAHC asked CMS to eliminate or rephrase the item.

Result: CMS eliminated the item. But it incorporated the measure into the new plan of care grid in M2250 (see more on that new item below).

If it stays the same as in Version 12.1, the grid will ask about patient-specific parameters, but give HHAs a "not applicable" option that says,"Physician has chosen not to establish patient-specific parameters for this patient. Agency will use standardized clinical guidelines accessible for all care providers to reference."

Providers also had problems with the socalled "plan of care" questions added to the OASIS form, St. Pierre tells Eli. Six items on the November OASIS C form asked about the presence of processes in the plan of care.

For example: Item M1244 on the tool said,"Planned Pain Intervention: Does the current physician ordered plan of care include intervention(s) to monitor and mitigate pain?" with "yes" or "no" responses.

"Since the OASIS questions about the presence of processes in the plan of care...are not gathered at transfer or discharge, it appears that these items are simply present to prod clinicians to include them, rather than to measure agency performance in this area," NAHC noted in its comments. This type of information could be assessed during a survey rather than collected in OASIS.

The M0 items are also confusing because they ask if the physician-ordered POC includes them, but the POC is established with the physician after the comprehensive assessment, NAHC added.

"Many providers are also just entirely resistant to any process measures, feeling that it interferes with the ability of nurses to exercise their clinical judgment," notes Chicago-based regulatory consultant Rebecca Friedman Zuber. Home care folks "either welcome them or just resist them because of the principle of the thing."

The good news: If the changes in version 12.1 stay the same, CMS has deleted the individual questions on whether the POC contains processes,says consultant Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C. Instead, CMS added a new question (M2250) with a grid where providers must note whether interventions related to processes are included in the POC.As with the question on parameters, clinicians can choose a "not applicable" option for the intervention.

"The new ... grid is easier to see and probably to complete, so that is a positive,"Adams tells Eli.

The bad news: "The companion questions on whether interventions were implemented since the last OASIS assessment have all been revised and now ask if both the interventions are on the physician ordered plan of care and if they have been implemented," Adams laments. That "appears to me to be very duplicative."

CMS has "reduced the number of items that require you to look back and see what was ordered at the start of care," Friedman Zuber allows. "But there will still be too much of that."

It appears CMS also will address another new M0 item agencies didn't like, M0102 regarding date of physician referral, points out St. Pierre. CMS switched the item with the one on start of care date,so M0102 now refers to the referral date and M0104 now refers to the SOC date.

Then: In the OASIS C version proposed in November,M0102 said, "Indicate the date the physician made the referral for this home health Start of Care (Resumption of Care)."

Now: If it stays the same as Version 12.1,the new version at M0104 says, "Indicate the date that the written or documented orders from the physician or physician designee for initiation or resumption of care was received by the HHA."

"Referral practices vary, with many referrals made by individuals other than the physician,"NAHC noted in its comments. "Also, situations often arise where patients are not available for care on the physician order start of care date," the trade group added.

"CMS has tried to be responsive to concerns expressed by providers," Friedman Zuber says.

Depression screening: CMS also has made changes to one of the most controversial of the new process measure-related items,M1730 about depression screening.