Home Health & Hospice Week

You still have to hit 70 percent in July.

Gear up to reach Medicare’s new minimum submission requirement for OASIS by next summer, or risk a pay reduction and possible survey trouble.

Starting July 1, home health agencies will have to hit a minimum OASIS submission threshold of 70 percent under Medicare’s newly finalized “pay-for-reporting performance system model,” the Centers for Medicare & Medicaid Services says in the 2015 home health prospective payment system final rule issued Oct. 30. That means HHAs must successfully submit an OASIS record for 70 percent of those episodes qualifying as a “quality episode of care,” according to the rule published in the Nov. 6 Federal Register.

CMS did not bend to commenter pressure to push the start date off a year or more. “We believe that use of the 70 percent standard is one that is attainable by any HHA, whether it is a large corporate entity or very small family run business,” CMS says in the rule. “HHAs have been statutorily required to report OASIS for a number of years and therefore should have many years of experience with the collection of OASIS data and transmission of this data to CMS. Given the length of time that HHAs have been mandated to report OASIS data, we believe that HHAs will adapt quickly to the implementation of the ‘pay-for-reporting’ performance requirement.”

However: CMS does relent on requiring agencies to meet an 80 percent benchmark in 2016 and 90 percent benchmark in 2018. “After carefully considering the comments submitted, we have reconsidered our proposal for implementation of a ‘pay-for-performance’ performance requirement over a 3 year period,” CMS says in the rule. “The ‘pay-for-reporting’ performance requirement is a new reporting requirement that can have a significant financial impact any HHA that is not able to meet the requirements.”

CMS eased up on the subsequent year deadlines, even after the Medicare Payment Advisory Commission advised the agency to keep to the new benchmark schedule.

Instead: “We plan to monitor provider performance under the ‘pay-for-reporting’ performance requirement during the time period of July 1, 2014 through June 30, 2015,” CMS explains. “We will then use such information, as available, to make a determination about what the ‘pay-for-reporting’ performance requirement will be set at in the 2nd and subsequent years.”