Home Health & Hospice Week

In addition to axing some items at followup, CMS will also add a few.

Just when you are getting used to the significant changes in OASIS-D, it’s time to start thinking about the next update to the patient assessment tool.

OASIS-D1 will take effect Jan. 1, 2020, confirmed a Centers for Medicare & Medicaid Services official in the agency’s April 3 Home Health Open Door Forum. The update will implement changes contained in the 2019 HH Prospective Payment System final rule.

CMS plans to release the draft OASIS-D1 instrument and related guidance in “early summer,” a CMS official said in the call.

Reminder: The final rule summarizes that OASIS-D1 will “make 19 current OASIS items (48 data elements) optional at the follow-up (FU) time point starting January 1, 2020” and will “add the collection of two current OASIS items (10 data elements) at the FU time point starting January 1, 2020” (see box, p. 101, for specific items).

CMS is making the changes because the Patient-Driven Groupings Model won’t require those items to adjust payments in subsequent billing periods, CMS explains in the rule. “Continuing to require HHAs to report responses for the 19 current OASIS items at the FU time point that are no longer needed for case-mix adjustment purposes under the PDGM results in unnecessary burden for HHAs,” the agency concludes in the rule.

Overall, data collection for 23 items will become optional at some time points in OASIS-D1, the CMS staffer summarized in the forum. That translates to 43 data elements in all, CMS says in the final rule.

What does it mean to be “optional” on OASIS-D? “HHAs may enter an equal sign (=)” for the optional items, CMS explains in the final rule.

In addition to the followup changes, CMS will remove one data element at SOC, one data element at ROC, three data elements at Transfer to Inpatient Facility, and three data elements at Discharge “associated with OASIS item collection as a result of the measure removals from the HH QRP and the implementation of the PDGM starting January 1, 2020,” CMS explains (see specific data elements in box, p. 101).

Don’t overlook: CMS also will “add the collection of two current OASIS items (10 data elements) at the FU time point starting January 1, 2020,” the agency notes in the rule. Those are M1800 (Improvement in Grooming) and M1033 (Risk for Hospitalization).

OASIS-D1 Change Will Save Agencies $60 Million, CMS Estimates

The addition will result in only a “small burden,” according to the rule. “Those two OASIS items (M1800 and M1033) are correlated with increases in resource use and are used to determine the patient’s functional impairment level under the HHGM, thus they are important for case-mix adjustment purposes in order to ensure accurate payments to HHAs under the PDGM,” CMS reasons.

Overall, CMS estimates the OASIS-D1 changes will save HHAs time and money. “We estimate the total average decrease in cost associated with changes with OASIS item collection at $5,148.94 per HHA annually, or $59,846,101.27 for all HHAs annually,” according to the final rule.

Time crunch: The nearly $60 million in annual savings “corresponds to an estimated reduction in clinician burden associated with changes to collection of information associated with the OASIS of 72.8 hours per HHA annually, or 845,881.3 hours for all HHAs annually,” CMS explains.

Note: The final rule is at www.govinfo.gov/content/pkg/FR-2018-11-13/pdf/2018-24145.pdf.