Home Health & Hospice Week

HHAs see M2030 downcodes.

Don't be surprised if medical reviewers are quicker to take your Medicare dollars back based on inaccurate OASIS answers.

In the latest Comprehensive Error Rate Testing results, CERT reviewers reduced home health agencies' HIPPS codes due to errors in M2030 -- "Patient's current ability to prepare and take all prescribed injectable medications reliably and safely, including administration of correct dosage at the appropriate times/intervals. Excludes IV medications." In the downcodes, "responses to this OASIS item ... were inconsistent with the documentation submitted by the provider," notes HHH Medicare Administrative Contractor CGS in its review of the CERT results in its June newsletter for providers.

In the majority of cases, "the documentation did not indicate that the beneficiary was receiving any injectable medications" even though the clinician chose a response indicating the patient was receiving injectable meds, CGS notes.

Chicago-based regulatory consultant Re-becca Friedman Zuber is surprised to see this problem rank as one of the top HHA claims errors. "I have not often seen reviewers draw a direct line from an error on OASIS to a recoupment in anything other than therapy," Zuber notes.

HHAs must tread a careful line with OA-SIS accuracy, experts warn. Authorities could view OASIS errors that result in higher payment as deliberate falsifications -- in other words, fraud and abuse.

Try this: To avoid OASIS-related takebacks, implement a stringent OASIS review process, advises consultant Lynda Laff with Laff Associates in Hilton Head Island, S.C. HHAs can consider a manual review process -- having an OASIS-C certified nurse review the OASIS and ensure clinicians make all appropriate corrections. Or agencies might want to use a data scrubbing tool to review for diagnosis issues and OASIS item inconsistencies, Laff suggests.

Staff training on OASIS errors you find -- both one-on-one and in a group setting -- are key followups, experts counsel.

For example: For one of the CERT downcodes based on M2030, the clinician marked that the patient was receiving injectable meds even though the B12 injections were being administered at the doctor's office. But the OASIS-C Guidance Manual updated this January specifically states that the question "excludes IV medications, infusions (i.e., medications given via a pump), and medications given in the physician's office or other settings outside the home."

Here are a few more tips on how to correctly choose a response to M2030 from the OASIS-C Best Practice Manual from Fazzi Associates:

1. Include assessment of ability to not only draw up and administer injection but to also dispose of syringe properly.

2. Conduct assessment prior to initiation of teaching to establish baseline performance.

3. For patients on multiple injectable medications, score based on that medication with which most assistance is needed.

4. Orders for a nurse to administer the injection infers that the patient is unsafe/unable to self-inject: select response 3 -- Unable. v

Note: Item-specific guidance from CMS is in Chapter 3 of its OASIS-C Manual at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIOASISUserManual.html (scroll down to "2011 OASIS-C Manual" in the Downloads section). Fazzi's Best Practice Manual is at www.deltahealthtech.com/assets/docs/OASIS%20C%20Best%20Practice%20Manual.pdf.