Home Health & Hospice Week

It’s not too early to start preparing your agency for the big OASIS revamp.

To reduce the pain when OASIS-C hits about a year from now, you’d better start getting ready right away.

Last month, the Centers for Medicare & Medicaid Services issued its latest draft of the OASIS retool. The new form for home health agencies makes widespread changes, including the addition of numerous process-based items on care provision timeliness; physician notification; immunizations; risk assessments, care planning, and interventions for pain, depression, falls, and pressure ulcers; interventions for diabetes, heart failure, and pressure ulcers; and drug reviews and teaching (see Eli’s HCW, Vol. XVII, No. 42, p. 330).

While OASIS-C will undergo some tweaks before CMS issues the final version next year, it’s not too early to begin preparing for the big change, says Ann Rambusch with Rambusch3 Consulting in Round Rock, Texas.

"I definitely think agencies should start planning now," agrees Chicago-based regulatory consultant Rebecca Friedman Zuber. With so much to do before the new form hits in January 2010, agencies need all the time they can get to prepare.

Just training on the new form will take up a good deal of time and resources, points out consultant Judy Adams with LarsonAllen based in Cha-rlotte, N.C. "There will certainly need to be considerable re-education for clinicians on the OASIS form and the individual questions," Adams predicts.

Here are the steps these experts recommend you take now to prepare for OASIS-C:

1. Review the rule. Get to know the OASIS changes that are in store for you. "Agencies should download a copy of OASIS-C and study it," Ram-busch urges.

Be sure to submit your comments on the new form by Jan. 13, Adams adds. Providers should be sure to note "any items they feel are unclear or unnecessary, as well as any topics they believe may be missing from the form," she tells Eli.

2. Take stock of your processes. Now’s the time to take a hard look at your own procedures so you can prepare for the new process-based items, Friedman Zuber advises. Figure out which processes you already perform and which ones you’ll have to add or modify.

For example: "Many agencies already have fall risk assessments and utilize the Braden scale for pressure ulcer risk factors," Adams observes.

Agencies that are trying to reduce their acute care hospitalization rates may also already address immunization, depression, medication management, management of heart disease (especially heart failure), and involvement of caregivers, Rambusch adds.

While OASIS-C may undergo some changes, it’s a safe bet that the final form will still require these elements, experts say.

3. Map out your implementation plan. Once you know which processes you need to add, make a schedule for implementing them in advance of the OASIS-C start date. Training clinicians on the new tool will be easier if you’ve gradually introduced these procedures throughout the year, Friedman Zuber counsels.

"Begin asking some of these assessments now," Rambusch recommends.

4. Acquire tools for the assessments. "Many agencies may still need to implement … screening tools related to heart failure, fall risk, depression, and pressure ulcers," Adams expects. Identify tools for adoption early so you can choose the best ones for your agency, stagger their implementation, and avoid last-minute scrambling.

For example: For the new item requiring screening of all patients for depression, M1120, agencies can use a simple two-question tool called the PHQ-2 (Personal Health Questionnaire), recommended Elizabeth Madigan with OASIS contractor Case Western Reserve University at the National Association for Home Care & Hospice’s October annual meeting in Ft. Lauderdale (see Eli’s HCW, Vol. XVII, No. 37, p. 291). HHAs can easily find the tool on the Internet, she advised.

5. Develop and implement protocols. Screening tools aren’t the only things you’ll need to add for OASIS-C. The new form will ask about interventions as well.

"HHAs will benefit from developing and establishing standardized guidelines or protocols based on evidence-based practice for dealing with pressure ulcers, fall risks, heart failure, depression, diabetic foot care, and even parameters to consider for [physician] notification," Adams says. "Actual re-sponse for each of these topics would need to be individualized for specific patients, but the availability of approved guidelines within the agency would greatly enhance both consistency and appropriateness."

"These are all things they should get in place in their clinical processes this year if they don’t have them already," Friedman Zuber says.

6. Train staff. You’ll probably want to hold off on training staff on the new OASIS-C form until CMS finalizes the tool next year, experts agree.

Don’t wait: But you should begin training staff on the new tools and procedures surrounding the process-based measures, they stress. "Get staff oriented to [the assessments] and why they are being added," Rambusch advises.

Keep your last-minute training burden as light as possible by doing what you can earlier in the year, Friedman Zuber recommends.

7. Secure staff buy-in. Don’t forget to look at your attitude surrounding the new OASIS tool, Rambusch says. "If we grouse and grump about the new form, we send the wrong message to our staff," she warns. "Agencies … need to promote OASIS-C in a positive way."

Remind staff that the changes are patient-fo-cused and aim to improve care quality, she suggests. "We look on more paperwork as a burden, but this really has a potential for being good for us." v

Note: See the new OASIS-C form and its supporting documents (including a crosswalk from OASIS-B1 to proposed OASIS-C M0 items) at www.cms.hhs.gov/PaperworkReductionActof1995/PRAL/list.asp--searchforCMS-R-245.