Home Health & Hospice Week

Implementation will wait for COVID PHE’s end, CMS confirms.

The OASIS-E deadline is still at least 20 months away, but you can start prep this summer with new guidance and training from Medicare. The question is, should you?

Recap: Last year, the Centers for Medicare & Medicaid Services bumped OASIS-E from its Jan. 1, 2021 start date to give agencies a break during the COVID-19 public health emergency. “HHAs will be required to use OASIS-E … beginning with discharges and transfers on January 1st of the year that is at least 1 full calendar year after the end of the COVID-19 PHE,” CMS said in an interim final rule published in the May 8, 2020 Federal Register.

Then an announcement that CMS will furnish training and materials on the updated assessment tool this summer, made a few weeks back in the agency’s April 13 Home Health Open Door Forum, left agencies wondering if CMS may implement OASIS-E in January 2022 anyway (see HCW by AAPC, Vol. XXX, No. 15).

After all, CMS set a precedent of sorts for resuming activities before it originally projected when it restarted the Home Health Review Choice Demonstration in five RCD states. It originally said it would postpone the program until after the PHE ended, but it then restarted the program in Illinois, Ohio and Texas and launched RCD in North Carolina and Florida on a “voluntary” basis last August. While those agencies that don’t participate are not docked 25 percent as originally set out, it appears their claims will face 100 percent post-payment review when the PHE ends (see HCW by AAPC, Vol. XXIX, No. 31).

Now CMS has confirmed to AAPC that it is sticking with its originally announced implementation date for the next version of OASIS. “The policy established for the implementation of Outcome Assessment Information Set Version E (OASIS-E) is that home health agencies will be required to use OASIS-E to collect data on the two Transfer of Health Information Measures beginning with discharges and transfers on January 1st of the year that is at least 1 full calendar year after the end of the COVID–19 Public Health Emergency (PHE),” a CMS spokesperson says.

But training will proceed this summer. “Due to the delay in the release of the new OASIS-E because of the PHE, CMS will provide interim guidance,” the CMS source tells AAPC. “CMS will hold a training call this summer regarding key guidance affected by the delay in OASIS-E.”

The timing of OASIS-E’s implementation is a big deal for HHAs because the updated assessment tool is going to drop a big burden in agencies’ laps. “This will represent the largest OASIS changes in decades,” stresses Sherri Parson with McBee Associates in Wayne, Pennsylvania.

Adding the additional items for OASIS-E (see box, p. 123) will be “a big burden,” predicts Sharon Litwin with Healthcare Provider Solutions in Nashville, Tennessee. OASIS assessments already take “so long,” she notes.

The extra burden comes on multiple fronts, Parson points out. “The burden to agencies both in assessment completion time and training early on will be significant,” Parson expects.

In particular: “The burden for learning new assessments” — such as the Brief Interview for Mental Status (BIMS) and Confusion Assessment Method (CAM) — will be “a little time consuming,” cautions J’non Griffin with Home Health Solutions in Carbon Hill, Alabama.

“Any time additions to the OASIS occur, there is increased burden for providers, particularly at the beginning stages of implementation with education needed for the individual items including the way the responses are formatted,” points out Angela Huff with BKD in Springfield, Missouri. “There will be additional time required for clinicians to assess the items and document the responses that in turn will add time to the overall visit.”

That means “with eight items that have multiple selections and discussion required to complete the assessment, it will easily add a few minutes to complete these items even after the clinicians are comfortable with new content,” Huff offers.

Overall, OASIS-E is “very burdensome,” maintains the National Association for Home Care & Hospice’s Mary Carr. “Whenever I had an opportunity to submit comments on the measures and assessment items related to the IMPACT Act,” I’ve “tri[ed] to make that case,” she tells AAPC.

On the plus side, “there are also removals of outdated items,” highlights Cindy Krafft with Kornetti & Krafft Health Care Solutions. For example, CMS will eliminate

M1242 (Frequency of Pain Interfering with Patient’s Activity or Movement).

Staffing Crunch Necessitates Delay

Given the broad scope of the OASIS-E additions, the delay due to COVID is much needed, industry experts agree.

“Waiting will be the best course of action, since agencies are still very affected by the PHE, even from a staffing standpoint,” Parson observes. “It is prudent that there is a bit of a delay to help agencies adjust and train towards the OASIS-E changes.”

This far into 2021, “this coming January would be too soon and not allow for the required training, which would lead to a rockier implementation,” Huff predicts. “Providers have been stretched with the impact of the pandemic and have done considerable shifting to adjust,” she adds. “The delay will allow providers to shift their focus and give OASIS-E the required attention that it deserves.”

The implementation needs don’t stop with training, Litwin points out. Providers “will need to audit and check it a lot” once OASIS-E goes into effect, she says. “It’s too much change. Agencies can’t prepare during a pandemic,” she judges.

“I personally would want to see OASIS-E sooner, as many of the changes are positive,” Krafft says. “But I understand that with everything else going on, it may be too much for the industry.”

“I don’t want see the implementation date moved up to January,” Carr maintains. “HHAs need the extra time in light of the PHE.”

Keep in mind: Training may be more complex than it first appears. “OASIS-E represents more than just new assessment items, but a new approach to health care that promotes interoperability, safety and equity,” Parson explains. “Getting the concepts and vision behind these changes will be as important as the assessment items themselves.” (For training advice from the experts, see a future issue of HCW by AAPC). v

Note: The draft OASIS-E instrument is at https://www.cms.gov/files/document/draft-oasis-e-all-items03122020.pdf. A change table is at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/Change-Table-for-Proposed-HH-QRP-Items-Effective-January-1-2021.pdf.