Home Health & Hospice Week

Don't let surveyors ding your assessments.

How confident are you in your non-OASIS comprehensive assessment procedures? You may want to take another look at them following recent instructions to state surveyors.

The Centers for Medicare & Medicaid Services clarifies in a Sept. 9 letter to surveyors that agencies must conduct an update to the comprehensive assessment as often as the patient's condition warrants it, and "not less frequently than the last five days of every 60 days" for all patients, regardless of payor source.

When CMS announced it was suspending OASIS collection for non-Medicare, non-Medicaid patients back in November, many agencies erroneously stopped conducting followup comprehensive assessments on those patients as well, says consultant Judy Adams with Charlotte, NC-based LarsonAllen Health Care Group. In an April letter and again in its most recent missive, CMS stresses that comprehensive assessments are indeed required.

But CMS leaves a lot of leeway for agencies in designing their own assessments, notes Chicago-based regulatory consultant Rebecca Friedman Zuber. CMS' recent surveyor letter reaffirms that agencies have the right to design their own comprehensive assessment for non-OASIS patients and administer the assessment on their own timeline, Adams points out.

How can you make sure your comprehensive assessment for non-OASIS patients won't get you into hot water with surveyors? First take a look at the standard at 484.55, advises Rachel Hammon of the Texas Association for Home Care: The HHA must furnish for each patient "a patient specific, comprehensive assessment that accurately reflects the patient's current health status and includes information that may be used to demonstrate the patient's progress toward achievement of desired outcomes. The comprehensive assessment must identify the patient's continuing need for home care and meet the patient's medical, nursing, rehabilitative, social, and discharge planning needs."

Then keep these tips in mind when crafting your assessment:

1. Topics covered. Don't fall into the trap of assessing only patients' systems, Zuber advises. Be sure to take into account patients' environments and how they manage in the environments. Looking at the areas covered by the OASIS assessment can help. "A comprehensive assessment ought to touch on all those OASIS categories, just not in the same way," she says.

Comprehensive assessments typically address physical, mental, social, environmental and ADL/IADL aspects of the patient's condition, Adams adds. The items covered should allow the clinical staff to develop an appropriate plan of care to meet that patient's needs.

2. Customizing. The beauty of using a non-OASIS assessment is that you can customize it to your patient population. While OASIS is geared toward the elderly population, you can design your assessment toward your target patients, Zuber counsels.

"The actual elements in this assessment could vary from agency to agency depending on the specific types of services to be provided," Adams says.

3. Tools. Agencies should strive to make their assessments as objective as possible, Zuber suggests. There are many more standardized tools, such as wound care scales or physical therapy scales, clinicians now can use to assess a patient's condition. HHAs should use them when feasible, Zuber urges.

4. Policies. You should spell out your non-OASIS assessment in your policies and procedures and then make sure clinicians stick to it, Zuber notes. Likewise, the timeframe for the assessments should also be clear and enforced, Adams says.

5. Charting by exception. HHAs that want to save time on their comprehensive assessment updates can consider charting by exception - that is, noting only the changes from the patient's initial assessment, Hammon suggests.

CMS has spelled out that agencies must conduct a brand new OASIS assessment at every assessment time point, Hammon acknowledges. But CMS said in the OASIS regs that "for the remainder of the comprehensive assessment that does not include the OASIS items, limiting documentation to the changes in the patient's assessment is acceptable," according to Hammon.

Agencies can take that as a blessing on a charting by exception policy, Hammon concludes.

Many agencies decide to retain the OASIS assessment for all their patients' comprehensive assessments, Adams notes. They may want to avoid the confusion caused by having two or more types of assessments, and the possibility of accidentally not conducting an OASIS assessment when required. And sometimes HHAs find out patients are eligible for Medicare after the episode is entirely over.