Have you been wondering if Medicare would follow through on penalizing home health agencies for late or missing OASIS data? You might get a clue from a new audit topic picked up by two Recovery Audit Contractors. The RACs for Region A (Diversified Col-lection Services) and Region B (CGI) have posted "Late Submissions of IRF-PAI Data," as topics. Inpatient rehabilitation facility-patient assessment instrument (IRF-PAI) data, which is collected on a Medicare Part A fee-for-service inpatient, must be transmitted to the Centers for Medicare & Medi-caid Services National Assessment Collection Data-base by the 17th calendar day from the date of the patient's discharge. Transmission of the IRF-PAI data record 28 or more calendar days after the discharge date will result in the claim incurring a 25 percent late transmission penalty. It would be easy for the RACs to crunch data and find late and missing OASIS data for home health claims too, observers note. HHAs are supposed to have a 2 percent across-the-board rate cut when they fail to submit OASIS data on time. In a February report, the HHS Office of Inspector General slammed CMS for failing to penalize HHAs when they have late or missing OASIS data (see Eli's HCW, Vol. XXI, No. 9, p. 66). CMS pledged to get on the case.