Home Health & Hospice Week

OASIS submission a new must.

Why are your OASIS submissions so important to Medicare — important enough to stop your reimbursement for medically necessary care furnished to eligible patients?

You may want to thank the HHS Office of Inspector General. In 2012, the OIG published a report criticizing how the Centers for Medicare & Medicaid Services ensured home health agencies met their regulatory obligations regarding OASIS data. “In 2009, 85 percent of HHAs did not submit OASIS data for at least one claim,” the OIG said in the report. “Over half of those HHAs did not submit OASIS data for at least 10 claims in 2009.” (See more about the report in Eli’s HCW, Vol. XXI, No. 9.) HHAs also submitted about 15 percent of OASIS datasets past the 30-day required deadline in that year, the OIG found. That was unacceptable for data that drives payment and quality, the OIG said. CMS has made a number of OASIS-related changes since the OIG issued the report, notes Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tenn. That includes switching OASIS submission away from state databases over to the federal ASAP system in January 2015 and implementing an edit in April 2015 that recodes a claim’s HIPPS code to match the OASIS on file if it is present (see Eli’s HCW, Vol. XXIV, No. 12). CMS had tested the assessment data-claim matching technique with Inpatient Rehab Facilities first in 2013 and 2014.

Think of the OASIS submission like securing a physician’s signature on the plan of care, Gaboury suggests. “You can’t just say ‘I sent the 485 to the physician and he didn’t sign it, but I’m going to bill anyway,’” she explains. Confirmed OASIS submission is a must before billing.

Note: The OIG’s report is at https://oig.hhs.gov/oei/reports/oei-01-10-00460.pdf.