Home Health & Hospice Week

Expect the holiday crunch to crank up to ‘11’ this year, with OASIS-E and VBP debuting simultaneously Jan. 1.

New OASIS-E information released by Medicare underscores how much extra work will be dumped on home health agencies’ plates in about 10 short months.

The Centers for Medicare & Medicaid Services has released its Paperwork Reduction Act packet seeking Office of Management and Budget approval for the OASIS-E assessment tool that will take effect Jan. 1, 2023. In addition to the 32-page tool itself, the packet contains an OASIS-D1-to-OASIS-E change table, a list of data elements, and a supporting statement calculating the increased burden and cost of the new instrument, among other things.

Reminder: In 2020, CMS bumped OASIS-E from its Jan. 1, 2021 start date to give agencies a break during the COVID-19 Public Health Emergency. It said it would implement OASIS-E the year after the PHE ended. But in the 2022 home health final rule, CMS cut the PHE reprieve short by finalizing January 2023 as the new OASIS-E implementation date (see HCW by AAPC, Vol. XXX, No. 40-41).

“This OASIS version reflects a net increase of 143 data elements (DE) across all time points … from OASIS-D/D1,” CMS specifies in the PRA supporting statement. (See the new OASIS-E items in story, p. 51.)

“In our estimations, we assume that data elements require a range of 0.15-0.3 minutes of clinician time to complete,” CMS says. The agency calculates that “the total burden hours have increased from 9,984,576 to 13,139,904 for a net change (increase) of 3,155,328 hours,” it explains.

It’s not just time filling out the instrument that will increase costs. Administrative and training time will also go up, CMS notes in the statement. Training on OASIS-E alone will cost HHAs $23.4 million, the agency estimates.

The bill: Implementing and using OASIS-E will cost $993.9 million, CMS concludes in the PRA statement.

And that nearly-billion-dollar figure is actually too low, contends the National Association for Home Care & Hospice. “As usual, in the supporting statement …CMS underestimates the burden for HHAs to complete the OASIS-E data set,” NAHC says in its member newsletter.

“CMS projects that assessment items in the data set will take a range of 0.15-0.3 (9-18 seconds respectively) minutes of clinician time to complete,” NAHC points out. “This assumption provides that even the most complex assessment items (e.g. the GG items and the new cognition items) will require, at most, 18 seconds to complete,” the trade group stresses.

“OASIS-E now has many assessment pieces that will add to the completion times of the OASIS,” observes Sherri Parson with McBee Associates in Wayne, Pennsylvania. “The assessment will be of an interview format with specific guidance around these items for implementation and scoring that the clinician will need to get familiar with,” Parson says.

Increased costs underpins many of the challenges agencies are facing in implementing OASIS-E, including:

• Value-Based Purchasing. Like OASIS-E, Home Health VBP will take effect Jan. 1. “Implementing two major changes will be overwhelming to many agencies that have not begun preparing in advance,” Parson warns.
• Training timing. Due in large part to VBP, HHAs are less sure than usual of when to start training, offers Cindy Krafft with Kornetti & Krafft Health Care Solutions. Remember, OASIS-E implementation is “combined with moving from practice to real HHVBP that same month,” she stresses.
• Staffing. The staffing shortage that is making everything else in home health difficult will take its toll on OASIS-E prep as well. “Staffing challenges” top agencies’ list of things to overcome regarding OASIS-E ramp-up and implementation, Krafft notes.
• Holidays. And just to make training timing and staffing challenges worse, OASIS-E and VBP will hit right in the hectic holiday season, notes consultant Angela Huff with BKD in Springfield, Missouri.
• Content. “A new OASIS is always an additional challenge for organizations to ensure that staff are educated on the tool and the guidance surrounding the items for assessment,” Huff acknowledges. But OASIS-E is no bare-bones, simple update. With the sometimes complex cognitive interview and

SDoH included in the tool, getting staff totally up to speed by implementation day will pose particularly challenging.

Keep An Eye On 2023 Rule

In the PRA supporting statement, CMS also signals that it’s got more changes in store regarding OASIS and the Patient-Driven Groupings Model.

It lists the following as “changes pending proposal in the CY2023 rule. The addition of items to the Follow-up time point to support [case mix] potential updates to the home health PDGM”:

• GG0130E. Shower/bathe self
• GG0130F. Upper body dressing
• GG0130G. Lower body dressing
• GG0130H. Putting on/taking off footwear
• GG0170G. Car transfer
• GG0170K. Walk 150 feet
• GG0170O. 12 steps
• GG0170S. Wheel 150 feet.

Note: A link to the ZIP file containing the PRA packet documents is at https://www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-10545

For OASIS-E prep tips, see an upcoming issue of HCW by AAPC.