Home Health & Hospice Week

Medicare wants to see assessment data on all your patients — including those with very short stays.

For nearly the first time since OASIS’ inception almost 25 years ago, the rules on which patients HHAs will have to collect data on is about to change.

In the 2023 home health proposed payment rule, the Centers for Medicare & Medicaid Services “proposes to end the suspension of the collection of Outcome and Assessment Information Set (OASIS) data on non-Medicare and non-Medicaid patients … and to require HHAs to report all-payer OASIS data for purposes of the [Home Health Quality Reporting Program], beginning with the CY 2025 program year.”

Background: When CMS launched OASIS in 1999, HHAs initially raised privacy concerns about collecting OASIS data for non-federal-payer patients, and then a report required by law noted that the data wouldn’t be used by CMS anyway due to Medicare/Medicaid vs. private payer patient differences, CMS recounts in the rule. Since then, “CMS has laid the groundwork for the resumption of all-payer data submission because we want to represent overall care being provided to all patients in an HHA,” the rule says.

“The concerns raised surrounding privacy ... have been mitigated,” CMS contends. “CMS data systems conform to all applicable Federal laws, regulations and standards on information security and data privacy.”

And “collecting OASIS data on all HHA patients, regardless of payer, would align our data collection requirements under the HH QRP with the data collection requirements for the LTCH QRP and Hospice QRP,” CMS says in the rule. “We also believe that the most accurate representation of the quality of care furnished by HHAs is best captured … using OASIS data submitted on all HHA patients, regardless of payer.”

New risk adjustment models would help with the differences in patient populations and the ability to compare quality across post-acute payers would be important, CMS says.

Timeline: “For the CY 2025 HH QRP, the expanded reporting would be required for patients discharged between January 1, 2024, and June 30, 2024,” CMS proposes. “Beginning with the CY 2026 HH QRP, HHAs would be required to report assessment-based quality measure data and standardized patient assessment data on all patients, regardless of payer, for the applicable 12-month performance period (which for the CY 2026 program, would be patients discharged between July 1, 2024, and June 30, 2025).”

Burden, Shmurden

“The proposed requirement for OASIS to be submitted for all payers in 2025 is no small change … for some organi­zations,” says consultant Angela Huff with FORVIS, the new firm formed by the merger of BKD and DHG. The extra requirement will “add time and cost,” Huff tells AAPC.

“It feels like with every turn of the page of this rule, there is significant impact to an already burdened industry,” Huff laments.

“This additional OASIS data collection will not only impact the productivity of agencies' clinical staff, but the OASIS data on all of these new patients will be used for the Home Health Quality Reporting Program and appear on Care Compare and your Star Rating,” warns Cypress, California-based software vendor HealthCare Synergy in online analysis.

CMS is quick to dismiss the extra work for HHAs. “While we appreciate that submitting OASIS data on all HHA patients regardless of payer source may create additional burden for HHAs, we also note that the current practice of separating and submitting OASIS data on only Medicare beneficiaries has clinical and workflow implications with an associated burden,” the agency says in the rule. Plus, “it is common practice for HHAs to collect OASIS data on all patients, regardless of payer source,” CMS argues.

Bottom line: “Requiring HHAs to report OASIS data on all patients will provide CMS with the most robust, accurate reflection of the quality of care delivered to Medicare beneficiaries as compared with non-Medicare patients,” the agency justifies.