Home Health & Hospice Week

In a matter of days, your hard work on OASIS C will be put to the test, with your payment, outcomes, and compliance record hanging in the balance. Home health agencies are stretched to the breaking point over the major change to the patient assessment tool. "I haven't seen this much apprehension in the home care environment in a very long time," notes consultant Pam Warmack with Clinic Connections in Ruston, La.

Use these expert tips to make your OASIS C transition as smooth as possible.

1. Train staff. You should have already been training your staff on the myriad changes in the new OASIS instrument, experts agree. Now you're hitting the home stretch and it's time to stress the really important items.

Don't be afraid to repeat education you've already given for key points, says consultant Sharon Litwin with 5 Star Consultants in Ballwin, Mo. "OASIS C is complex." Repetition may be necessary for mastery learning.

And be sure to keep your training as practical as possible, Litwin urges. Many staff complain that they aren't learning the practical application of the new assessment tool.

2. Prioritize your topics. In the short span of time before OASIS C takes effect, you need to hit the most important and/or confusing items for education, experts recommend.

For many agencies, this will be the integumentary items, notes Lynda Laff with Laff Associates in Hilton Head Island, S.C. (See related story, p. 340, for guidance on those items).

That section has "quite a few changes versus OASIS B1," notes consultant Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tenn. Another crucial area for last-minute education are the items on medications, Warmack points out. Heart failure and activities of daily living are two more high-priority topics, Gaboury adds.

3. Use the right playbook. You should be basing your OASIS C education on the item-by-item guidance in the new OASIS C Guidance Manual's Chapter 3 (see related story, p. 342). But "make absolutely certain that you have pulled the correct OASIS C item guidance," Laff warns.

The problem: The Centers for Medicare & Medicaid Services' "initially published item guidance that was dated September 2009 for 2010 Implementation," Laff explains. Unfortunately, the revised version has exactly the same footer with only one very small difference, so it can be hard to tell if you're using the old or new version.

The solution: Check for this difference in the guidance documents: "The incorrect guidance document includes RM-201 at the bottom. The correct version has the same footer without the RM-201 at the bottom," Laff highlights.

"It is extremely important to ensure that the correct information is used," Laff stresses. "Anyone who pulled the original information could be using incorrect guidance to teach OASIS C. The changes for the wound care section are so major." Also be sure to use the information CMS has included in its 10-page "OASIS C Guidance Manual Errata" document on its OASIS C Web site, urges consultant Laura Gramenelles with Simione Consultants in Westborough, Mass. Due to the information in the errata, agencies "might need to go back and clarify a few things," Gramenelles suggests.

And include information from CMS's October question-and-answer set, Laff instructs.

Those Q&As, which are available on the OASIS Certificate and Competency Board Web site (www.oasiscertificate.org) under the "Resources" tab, spell out some wound care guidance, for example.

"This will be the only source to catch these corrections," Laff notes.

4. Stress documentation. Don't lose sight of the importance of documentation in your OASIS efforts, says physical therapist and consultant Cindy Krafft with Fazzi Associates in Northampton, Mass. The documentation is necessary to answer the new process measure items, plus "documentation of care is a critical element that extends beyond OASIS," Krafft emphasizes.

You should already have instructed staff on how to document and capture the information related to process measures, Gramenelles adds. Now is the time to drive home that message.

5. Widen your education net. You may be focusing your OASIS C education on your nurses and therapists who fill out OASIS, but you also need to be including other clinicians in your efforts, experts agree.

"The LPNs/LVNs should be included in this training, as their care will be questioned when the patient is discharged," Warmack explains. "They need to understand about the 'look-back' questions on the transfer and discharge OASIS," particularly for the cardiac and plan of care implementation items.

Also include therapy assistants (PTAs and COTAs) in your training, Krafft urges. "The care they deliver will impact process measures and attention to detail will be key," Krafft tells Eli.

6. Add physicians to your list. You may not be looking forward to it, but you'll need to educate your referring physicians on the OASIS items that address notifying physicians and receiving acknowledgment and/or order changes within a set timeframe. "Physicians must be inserviced about issuing patient-specific parameters and responding timely to notice of significant medication issues," Warmack says.

The new questions on physician notification will be one of OASIS C's big challenges, Gramenelles predicts. If you haven't already, you'll need to set up the process for how you plan to solicit that information from the physician, and how you plan to document that you completed the step and received the information back.

7. Implement your new tools. The process measure and physician notification items will be much easier to fill out accurately if you implement some new tools in your operations, experts agree.

Warmack recommends using a tool in the chart for tracking vaccinations and pressure ulcers.

The tool should be "kept as simple as possible" and "kept at the front of the chart so it can be very easily located and updated," she advises. Gramenelles counsels you to look at your processes and decide which process measure items would be easier to answer with a flowchart-type document in the chart.

For example: For the falls risks, you can have a flowchart that records the screening with a standardized assessment, the identification of falls risks, and the interventions that went onto the plan of care. That way, at discharge or transfer, a clinician can quickly look at the flowchart instead of combing through every progress note to see whether those items were done, Gramenelles explains.

Don't forget: With your process measure screening items, be sure to set a "threshold for action" for each item, Warmack says.

8. Nail down billing and IT issues. "Make sure that you clearly understand how your IT system will present OASIS C," Laff counsels. For example, if your IT system offers the risk assessments as "optional" and allows staff to skip them, be sure you educate staff heavily on why they should not pass them over.

And to make answering the process measure items easier, "assist with a report for the look-back questions answered at discharge and transfer," Laff recommends.

Be sure your policies and procedures are in place to ensure that you transmit start of care OASIS assessments, as well as followup/recerts, to the state prior to sending in the final claim, Gaboury advises.

And be sure you confirm that the HIPPS code generated by that OASIS assessment matches the code you are billing on the claim.

Tip: As soon as the OASIS C systems are up and running on Jan. 1, make sure your software is calculating the HIPPS code correctly with a test run, Gaboury says.

9. Be positive. Change this monumental is stressful for HHA management and staff. "All providers should proceed with their training with a very positive and reassuring style," Warmack suggests.

HHAs should realize "that staff competency with the OASIS will improve as everyone gets used to the new form," reassures Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C.

Agencies can deal with issues and questions that arise "one at a time come January," Adams adds. "Just like previous versions of OASIS, the educational process and revisions are an ongoing process."