Home Health & Hospice Week

Make collection decisions quick and easy with M0150. 

If you're revamping your OASIS procedures after the recent suspension of private pay data collection, you might have one more important consideration to factor in.

"There are some occasions where agencies still will want to collect private pay patients' data," warns Rosemary Nunn-Hill, the OASIS Education Coordinator for the state of Florida. Namely, when patients' primary payor is private insurance, and Medicare is their secondary payor.

Often, private insurance covers skilled nursing or therapy, but not home health aide services or dressing supplies that Medicare covers, Nunn-Hill explains. In those cases, and when the patient qualifies for the Medicare home health benefit by being homebound, needing a skilled service and having physician's orders for their care, the home health agency can bill Medicare for those other services.

The problem is, HHAs may not know right off the bat what the insurance will cover. And if they fail to collect the patient's OASIS data and insurance denies payment for Medicare-covered services, agencies can't bill Medicare for the items and services without the OASIS data, Nunn-Hill cautions.

So, if a patient meets the Medicare criteria and has Medicare as a secondary payor, agencies may want to be safe rather than sorry and go ahead and collect the data, she says.

One way to make collection decisions easier is by using M0150 on the OASIS tool, coding expert Prinny Rose Abraham suggested in a recent teleconference sponsored by Eli. The question asks for "Current Payment Sources for Home Care. (Mark all that apply.)"

If response 1 (Medicare [traditional fee-for-service]), 2 (Medicare [HMO/managed care]), 3 (Medicaid [traditional fee-for-service]), and/or 4 (Medicaid [HMO/managed care]) are marked, then clinicians should collect the rest of the OASIS data, Abraham explained. If other payors on the list are marked instead, then agencies can discontinue collecting the information.

And agencies should remember a comprehensive assessment is required for all patients, regardless of payor source, says William Dombi with the National Association for Home Care & Hospice. The big question is what will satisfy state surveyors in place of OASIS for a comprehensive assessment, Dombi notes.

Discontinuation of OASIS collection for private-pay patients has been slowed by the lack of an official word from the Centers for Medicare & Medicaid Services. Some OASIS state coordinators are telling agencies to hold off. "We are recommending HHAs wait for an official, written notice from CMS before changing their OASIS collection practices," says Arizona OEC Lynn Turner.

Many OASIS state coordinators, including those in Iowa, New Jersey, Georgia and Maryland, tell Eli they aren't commenting or issuing any guidance on the matter until CMS puts out a statement.

Others, including those in Oregon and Indiana, are merely passing along informal information they have received from CMS on the issue and letting HHAs make up their own minds. "I am letting them draw their own conclusions," says Ron Prinslow, Oregon's OEC.

But yet other OECs say it's very clear that CMS ceased requiring OASIS data for patients with non-Medicare, non-Medicaid payors Nov. 5. Based on a Nov. 6 email from CMS, "we are advising HHAs immediately that OASIS collection on private-pay patients is not required at this time," says Missouri OEC Mike DeClue.

The suspension was official as of Nov. 5, when CMS Administrator Tom Scully gave notice in the Open Door Forum, agrees Nunn-Hill and Pennsylvania OEC Janice Staloski (see Eli's HCW, Vol. XII, No. 40, p. 314).

A CMS spokesperson says there is no date set for issuing the official notice.