Home Health & Hospice Week

Warning: Lack of matching OASIS may flag your claims for medical review.

For now the Medicare claims system lets your claim process if there’s no matching OASIS on file. But don’t expect that exception to last for long.

“Submission of an OASIS assessment for all HH episodes of care is a condition of payment,” the Centers for Medicare & Medicaid Services notes in a MLN Matters article about the OASIS-HIPPS code matching edits that took effect April 1 (see related story, this page). “CMS plans to use the claims matching process to enforce this condition of payment in the earliest available Medicare systems release. At that time, Medicare will deny claims when a corresponding assessment is past due in the QIES but is not found in that system.”

An HHS Office of Inspector General report last year recommended that CMS deny claims when the OASIS wasn’t submitted or was submitted late, points out OASIS expert Lisa Selman-Holman of Selman-Holman & Associates, Code Pro University and CoDR — Coding Done Right in Denton, Texas (see Eli’s HCW, Vol. XXIII, No. 13). At the time, CMS said it had no way to determine whether the OASIS was submitted past the 30 days or whether it was on time but had to be corrected and reflected a later date, Selman-Holman says. CMS wanted to encourage correction so it declined the OIG recommendation. “Makes me wonder if they’ve got that fixed with the ASAP system,” she muses.

Just how long it will take CMS to begin denying claims with no OASIS is unclear. The requirement to match OASIS records with HIPPS claims was actually contained in a 2012 transmittal. CMS spent 2013 testing the matching process for inpatient rehab facilities (IRFs), then implementing it for IRFs in 2014. CMS began testing the matching process for HHAs last year.

Watch for: “CMS will provide notice to HHAs as soon as possible after we determine the implementation date” for the edits that will deny claims with no matching OASIS records, the agency adds in the MLN Matters article.

In the meantime, this will likely be a way to filter claims for medical review, warns Arlene Maxim of A.D. Maxim Consulting, A.D. Maxim Seminars and The National Coding Center in Troy, Mich. “No match means a review. The OIG is watching this, so it can’t be good news.”