Home Health & Hospice Week

Final OASIS-E is out — at long last.

If you, like many home health agencies, are fuzzy on when to use OASIS-D1 vs. OASIS-E at the end of the month, it could cost you in both time and money.

Reminder: OASIS-E, which is a significant update from the current version, is set to take effect on Jan. 1. Big changes include the addition of the Brief Interview for Mental Status (BIMS) in OASIS-E items C0100, C0200, C0300, C0400, and C0500; the Confusion Assessment Method (CAM) in C1310 A-D; and the Patient Health Questionnaire–2 to 9 (PHQ–2 to 9) in D0150 A-I and D0160.

In the Dec. 7 forum, a Centers for Medicare & Medicaid Services official noted that HHAs should decide whether to use the new or old OASIS version based on the M0090 date (Date Assessment Completed). There’s “no need for artificial M0090 dates” with this transition, she advised.

But that instruction left many listeners with questions, which they voiced in the question-and-answer portion of the call.

For example: One provider asked if she performed a recertification visit on Dec. 28, whether she’d use OASIS-E if the new episode begins on Jan. 1. The CMS speaker reiterated that the OASIS version is based on the M0090 date.

“The presenter is correct that whether the OASIS-D1 or the OASIS-E is the right one to use depends on the M0090 date,” observes Beth Noyce with Noyce Consulting. “If a recertification OASIS comprehensive assessment is being performed during the last five days of the 60-day benefit period, as it should, this still is the case,” Noyce tells AAPC.

“If the M0090 date is prior to Jan 1, 2023, the OASIS-D1 is the correct version to use, even if the new recert begins on or after Jan. 1, 2023,” Noyce continues. “That is the guidance,” she states.

“Having a M0090 date that is still in 2022 and the first day of the recertification period in 2023 is no cause for concern in Medicare’s view,” Noyce explains. “Any worries or potential stumbles might come from the timing of an electronic medical record vendor software update to accommodate OASIS-E implementation or other agency-specific parameters imposed.”

Tip: “Assessing clinicians who anticipate such issues should discuss the problem with their supervisors, and supervisors should consider any such issues ahead of time,” Noyce advises. That includes “anything they need to work out ahead of time with EMR vendors to facilitate the transition,” she points out.

Keep in mind: “An agency can make agency-specific rules that are more stringent, however, and add additional criteria, as long as it still meets the requirements in the OASIS-E Guidance Manual,” Noyce offers. “For example, the agency could choose to require all OASIS assessments begun during 2022 to also be completed during 2022, meaning the clinician may have to rush to gather all the required information in time to collect accurate data to complete the OASIS assessment before midnight Dec. 31, 2022, if that is the start-of-care date.”

Ultimately, using the correct OASIS tool comes down to avoiding wasted time and money. HHAs that see OASIS files rejected due to using the incorrect version “have to re-do it on the correct form,” Noyce points out.

Short Notice Proves Irritating

HHAs weren’t the only ones voicing frustration related to OASIS-E.

CMS issued the final version of the updated instrument on Dec. 6, along with a 12-page log of changes between the draft and final versions.

With the final version of OASIS-E out, “all systems are go,” notes OASIS expert Cindy Krafft with K&K Health Care Solutions.

“Based on errata that we just got … 25 days prior to the implementation date, I really want to encourage CMS to pay attention to the emails that are coming through and make sure that the answers are being put out there publicly as soon as possible,” urged a caller in the forum.

When CMS instructed providers with questions about which tool to use to submit questions via email, the vendor said “I’m a little frustrated that we’re making some policy updates by email less than 30 days from the implementation date,” she told CMS. “I think that we really need to have these questions about the M0090 date and what items need to be completed for those assessments that are going into that new year. It’s kind of frustrating from software development that we have a short period of time to make any kind of corrections if CMS makes any changes to that,” she vented.

Note: The final OASIS-E data set is in the “Downloads” section at www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/homehealthqualityinits/oasis-data-sets. The change log is at www.cms.gov/files/document/oasis-e-changes-draft-final-instrument-and-manual12012022.pdf.