Home Health & Hospice Week

You must submit data for every episode, CMS says.

Home health agencies that fail to submit OASIS data for every episode they furnish will face a 2 percent reduction to Medicare payment rates, according to new instructions from the Centers for Medi-care & Medicaid Services that takes effect in August.

"If a home health agency does not submit required quality data, their payment rates for the year are reduced by 2 percentage points," says May 11 Transmittal No. 2466 (CR 7833). "Original Medicare considers the following data as meeting the reporting requirement:

• OASIS data submitted by HHAs for all episodes beginning on or after July 1 of the previous year, and before July 1, of the current year, and
• Home Health Care Consumer Assessment of Health Providers and Systems (HHCAHPS) monthly data collection."

The transmittal revises data submission requirements that have been in effect since 2007. As expected, it adds HHCAHPS data for the first time. But the revision also changes the Medicare Claims Processing Manual (Pub. 100-04), chapter 10, section 120 to reflect the new definition of what satisfies the requirement that HHAs submit OASIS data.

Background: In 2009, 6 percent of Medicare home health agency claims did not have OASIS data for the same period, the HHS Office of Inspector General noted in a recent report, "Limited Oversight of Home Health Agency OASIS Data." About 85 percent of HHAs did not submit OASIS data for at least one claim that year, the report adds. And more than half of those HHAs did not submit OASIS data for at least 10 claims that year. (For more report details, see Eli's HCW, Vol. XXI, No. 9).

CMS told the OIG at the time that it was working on the problem and planned to have necessary system upgrades to correct it in place by October. Now it looks like that plan is on schedule, since the transmittal takes effect in August and will base reductions on a July-to-July calendar year.

Note: The transmittal and a related MLN Matters article are at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2012-Transmittals-Items/R2466CP.html.