Home Health & Hospice Week

Make sure staff know when rule of majority applies — and doesn’t.

You can bet even the most expert of OASIS staff are struggling under the weight of the OASISD transition. Here are some ways you can help.

Big difference: One of the most confusing differences between the M1800 items and the GG items is the rule of majority. For the M1800 ADL/IADL items, “if the patient’s ability varies between the different tasks included in a multi-task item, report what is true in a majority of the included tasks, giving more weight to tasks that are more frequently performed,” the Centers for Medicare & Medicaid Services instructs clinicians in the OASIS-D Guidance Manual.

In contrast, that rule does not apply to the GG items, stresses Sherri Parson with Quality in Real Time in Floral Park, New York. CMS highlighted that difference in its most recent quarterly question-and-answer set (see story, p. 36). “If one of the tasks requires partial assistance for any part of the included tasks for an item, then you will mark it ‘partial assistance,’” Parson instructs. Make sure staff know the difference, experts stress.

To help get your agency and staff up to speed on OASIS-D as quickly and efficiently as possible, consider this additional expert advice:

1. Lean on clinical collaboration. Reduce both staff’s and patients’ sense of being overwhelmed by pushing clinical collaboration, as allowed by CMS. “I think, and encourage, clinicians to take advantage of the clinician collaboration allowance in collecting all this assessment data,” recommends consultant Pam Warmack with Clinic Connections in Ruston, Louisiana.

In the OASIS-D Guidance Manual, CMS lays out these rules for collaboration: “While only the assessing clinician is responsible for accurately completing and signing a comprehensive assessment, s/he may collaborate to collect data for all OASIS items, if agency policy allows. Collaboration may consider information from others such as the patient, caregivers, and other health care personnel, including the physician, pharmacist, and/or other agency staff who have had direct contact with the patient or had some other means of gathering information to contribute to the OASIS data collection.”

Note that “when collaboration is utilized, the M0090 Date assessment completed should reflect the last date the assessing clinician gathered or received any input used to complete the comprehensive assessment, including the OASIS items,” CMS adds.

Elsewhere, the manual instructs agencies to “combine observation, interview, collaboration with other agency staff and other relevant strategies to complete any and all OASIS items as needed, unless otherwise noted in guidance. For example, it is acceptable to review the hospital discharge summary for information on a patient’s episodes of confusion, or to interview the caregiver regarding the patient’s incontinence. However, when assessing physiologic or functional health status, direct observation is the preferred strategy.”

2. Avoid ‘Patient Refused’ responses. Staff can avoid having to frequently answer “Patient Refused” for GG0130 and GG0170, Warmack offers. “Use the general observation and interview with the patient/caregivers that the guidance allows” to answer those questions, she urges.

The OASIS-D Guidance Manual notes that “OASIS data are collected using a variety of strategies, including observation, interview, review of pertinent documentation when allowed (for example, hospital discharge summaries), discussions with other healthcare providers where relevant (for example, phone calls to the physician to verify diagnoses), and measurement (for example, intensity of pain).” The manual later directs clinicians in general OASIS item conventions, telling clinicians to “combine observation, interview, collaboration with other agency staff and other relevant strategies to complete any and all OASIS items as needed, unless otherwise noted in guidance. For example, it is acceptable to review the hospital discharge summary for information on a patient’s episodes of confusion, or to interview the caregiver regarding the patient’s incontinence. However, when assessing physiologic or functional health status, direct observation is the preferred strategy” — but not the only strategy.

3. Plan for a learning curve. There are many details to grasp. “It will take clinicians some extra time to learn what is included in each item, and to also realize the ‘majority of tasks’ guidance does not apply to GG items,” Parson advises.

4. Point staff to Q&As. CMS has offered HHAs good clarifications in the many questions and answers issued since November. “All of the Q&As have been helpful,” Warmack judges. “At this stage in the game, clinicians should pay attention to all of the Q&As.”

Resources: To find the latest quarterly Q&As, which CMS resumed issuing this month, go to https://qtso.cms.gov/providers/home-health-agencyhha-providers/reference-manuals, scroll down to the “OASIS Quarterly Q&As” section and click on the most recent document. The 105-question set CMS issued after OASIS-D training last fall is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/November-2018-HH-QRP-Provider-Training-Q-and-A.pdf.

5. Support your staff. “Everyone is having to tread lightly and not overtax and frustrate field clinicians who are struggling to figure all of this out,” Warmack says.