Home Health & Hospice Week

First and foremost is fair compensation.

How determined are Medicare officials to move forward with all-payer OASIS? Home health agencies will soon find out when the Centers for Medicare & Medicaid Services issues its 2023 final rule.

In case CMS does decide to ignore the overwhelming, vociferous opposition from the industry on the matter, some proposed rule commenters offered some modifications to the change that would make it more workable.

For example: CMS’s bare bones proposal doesn’t lay out who may or may not be excluded from payer-agnostic collection. “In any future consideration of expansion to all-payer OASIS, CMS needs to include exemptions for Personal Care and Pediatric home health agencies” and patients, Jennifer Elder with the Texas Association for Home Care & Hospice suggests in the trade group’s comment letter.

And “if CMS decides to finalize this proposal, it should exclude patients who have transferred from Medicare fee-for-service to a Medicare Advantage Plan, and similarly exclude this information from Outcome Measures and Value-based Purchasing,” exhorts Neil Pruitt Jr. with PruittHealth in his comment letter. “Patients who have transferred from Medicare fee-for-service to Medicare Advantage plans will have already demonstrated progress and this will tend to skew our data,” Pruitt explains.

Patients who get approved for only a few visits should also be excluded due to a lack of ability to show improvement, multiple providers tell CMS.

Another popular suggestion is pushing back the implementation date. “There will be a long learning curve for clinical staff to become adept at completing the OASIS-E,” which goes live in January 2023, National Association for Home Care & Hospice officials note in the trade group’s comment letter. “Agencies will likely still be struggling with OASIS accuracy well into 2024,” NAHC predicts, so putting off implementation would be ideal.

“We do not support … the speed with which this proposed change would be implemented,” Joan Doyle, CEO of Penn Medicine at Home, says in her comment letter. “It does not provide for enough time for us to prepare for such a major undertaking” and “it does not reflect a realistic understanding of how much work would be involved,” Doyle says.

CMS should put off implementation until at least 2025, suggests Amanda Newell with the Tennessee Hospital Association in its comment letter.

Perhaps the most popular “if then” suggestion is compensating HHAs fairly for the extra work. “Delay the implemen­tation date until CMS has provided sufficient reimbursement to cover the additional costs for HHAs to collect and report the OASIS data on all patients,” NAHC recommends in its letter.

Stay tuned: See whether CMS heeds agencies' advice when it issues the final rule in late October or early November.