Home Health & Hospice Week

Tip: Give collecting patients’ vaccination info a trial run.

Avoid year-end chaos by starting the early stages of OASIS-E1 prep ASAP. Heed this expert advice:

1. Get to know OASIS-E1. Start out your implementation process smoothly by taking the time now to become familiar with the draft tool, which contains some significant changes (see related story, p. 27). “Reading the document is a good idea at the leadership level” right now, recommends Cindy Krafft with K&K Healthcare Solutions.

Tip: Once you’ve reviewed the new tool, “don’t be ‘doom and gloom’ about it with staff,” Krafft urges. “There is enough OASIS hate out there from the clinicians that we don’t need to fan the flames,” she maintains.

A link to the draft tool is in the “Downloads” section at www.cms.gov/medicare/quality/home-health/oasis-data-sets.

2. Start planning process updates ASAP. “OASIS E-1 changes will require some potential process changes for submission and data collection/verification of a patient’s COVID status,” as well as the switch to all-payer status, says consultant Angela Huff with FORVIS in Springfield, Mo.

COVID-19 vaccination changes will likely impact HHAs’ intake processes and policies, Huff predicts.

For HHAs that aren’t already submitting OASIS for all payers, the switch “will require education, potential [electronic medical record] updates and policy changes,” Huff tells AAPC.

“Evaluation of process submission and COVID-19 vaccination collection processes should be something that should start to be evaluated so that they are solidly nailed down before OASIS E-1 goes live,” Huff urges. If agencies conduct “solid groundwork” up front to generate updated processes that are clear and efficient, educating providers later this year on those changes “shouldn’t be too difficult,” she advises.

Don’t delay on this, Huff exhorts. “Start now with looking at the OASIS submission and COVID-19 data collection processes,” she urges.

3. Run down current patients’ vax info. More detail is needed from the Centers for Medicare & Medicaid Services regarding new item O0350 — Patient’s COVID-19 vaccination is up to date. But agencies can still “look at your current patients to see how readily that information is available now,” Huff suggests. “That will give agencies an idea of what steps they can put in place to get that information as early and easily as possible.”

Putting the work in now will prevent scrambling on this item later, she notes.

4. Keep watch for OASIS-E1 guidance. More details on the OASIS-E1 changes will be coming from CMS, but exactly when is an open question.

“Keep an eye out for the new OASIS E-1 Guidance Manual, which CMS indicated will be released later this year,” Huff says.

5. Get ready to comment. “Be aware of any comment period opportunities” that CMS or the Office of Management and Budget may offer, Krafft advises.

6. Update policies when the time is right. Agencies will want to finalize policies in accordance with the updates once they’ve gotten a look at CMS’ final guidance. But providers can start working on the policy changes now to minimize craziness later, especially if CMS waits until the eleventh hour to issue formal guidance.

Work on the front now will reduce year-end bedlam, Huff predicts.

7. Zero in on vaccination addition. O0350 will be the biggest change for most agencies, experts agree. Make sure to devote enough time and resources to the item in both the process and educational phases of preparation.

8. Reach out to EMR. “You will want to work with your EMR provider if there are going to be changes to set up needed for the OASIS submission updates for all OASIS for all payers requirements,” Huff points out. Don’t wait until the last minute to figure that out with them.

9. Pencil in staff education. Educating your OASIS staff can happen “later in the year,” Huff judges. But make sure your processes and policies are firmly in place before that.

Tip: “Once there is guidance, create a matter-of-fact approach to providing updates to staff in Q4 2024,” Krafft recommends.

10. Stress GG items too. While you’re at it, you may want to squeeze in OASIS education on GG items as well, offers Melinda Gaboury with Healthcare Provider Solutions.

Recap: CMS adopted Discharge Function as both a Home Health Quality Reporting measure and Value-Based Purchasing payment measure for 2025 in the 2024 home health final rule. DC Function is based on self-care (GG0130) and mobility (GG0170) items in Section GG, the reg specified.

In other words, CMS replaced the M1800 items in the ADL section with GG0130 and GG0170, Gaboury explains. “We have raised concerns about the inadequate GG education provided in numerous agencies,” she says. Many providers will need “more comprehensive education … for their field and [Quality Assurance] staff,” she says in her vlog.