Home Health & Hospice Week

Refreshed tool fails to jettison some unnecessary items, trade group says.

A reminder that you need to be on top of OASIS training this year has arrived.

Recap: In 2020, 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. But in the 2022 final rule, CMS cut the PHE reprieve short by finalizing January 2023 as the new OASIS-E implementation date (see HCW by AAPC, Vol. XXX, No. 40-41).

CMS issued a draft of the OASIS-E assessment tool back in 2020, but has now updated the OASIS-E draft tool with a new 32-page PDF file posted Feb. 1. “Please note the instrument is not yet final,” CMS says on its website. “Office of Management and Budget (OMB) approval is required and expected later this year.”

The new version of the draft contains changes from the old version, points out the National Association for Home Care & Hospice. “The updated version includes the addition of the ‘patient declines to respond’ in five of the items: Ethnicity, Race, Transportation, Health literacy, and D0700 Social isolation,” NAHC says in its member newsletter.

“CMS has also reorganized several of the items within sections and reassigned some items to new sections of the assessment tool,” NAHC explains.

Unnecessary items retained: A “puzzling aspect” of the updated OASIS-E draft tool “is that CMS has retained the items related to episode timing and therapy need,” NAHC highlights. “Both these items were necessary data set items for payment prior to the implementation of the Patient-Driven Groupings Model (PDGM), but are no longer required to establish a case mix grouping,” the trade group says.

CMS mandated the new January 2023 implementation date over industry opposition, including that HHAs couldn’t handle the workload while also battling COVID-related issues. “Based on a review of the current impacts of the PHE on HHAs nationally, we believe HHAs are well-positioned to successfully implement OASIS-E beginning January 1, 2023,” the final rule insists.

OASIS-E is important, CMS stressed. “The need for the Standardized Patient Assessment Data Elements and Transfer of Health data have shown to be even more pressing with issues of inequities that the COVID-19 PHE laid bare,” the 2022 final rule said. “This data that includes addressing SDOH provides information that is expected to improve quality of care for all,” so the revised compliance date “reflect[s] this balance,” it said.

“We are finalizing that HHAs will begin collecting data on the two TOH measures beginning with discharges and transfers on January 1, 2023 on the OASIS-E. We are also finalizing that HHAs will collect data on the six categories of Standardized Patient Assessment Data Elements on the OASIS-E, with the start of care, resumption of care, and discharges (except for the hearing, vision, race, and ethnicity Standardized Patient Assessment Data Elements, which would be collected at the start of care only) beginning on January 1, 2023,” CMS concluded in the final rule.

Note: The new version of the OASIS-E draft tool is at https://edit.cms.gov/files/document/draft-oasiseall-items-instrument-02012022.pdf.