Home Health & Hospice Week

Now is not the time to panic, OASIS expert stresses.

Just because the OASIS-E1 tool’s start date is a year away doesn’t mean you should put off action on the new assessment form.

Why? OASIS-E1 contains some big changes, such as collecting information on patients’ COVID-19 vaccination status and requiring OASIS for all patients regardless of payer, with a few narrow exceptions. “Working now to get the foundation set for implementation of [OASIS-E1] processes will prevent an end-of-the-year fire drill to get things in place,” advises consultant Angela Huff with FORVIS in Springfield, Mo.

It’s true that “we can’t really do much without the official guidance specific to any modifications/new items,” notes OASIS expert Cindy Krafft with K&K Healthcare Solutions. But smart home health agencies will familiarize themselves with the new tool now, so they can tackle action items in a timely manner later.

HHAs should “be informed, but not panic,” Krafft advises.

Pay Special Attention To This Hot Topic

At the top of agencies’ review list should be the deceptively simple new item on patients’ COVID vaccination status.

New item O0350 reads “Patient’s COVID-19 vaccination is up to date,” according to the draft tool released by the Centers for Medicare & Medicaid Services earlier this month. The tool instructs clinicians to “Enter Code 0. No, patient is not up to date [or] 1. Yes, patient is up to date.”

This item “is going to be a hot topic as we move forward,” expects Michelle Horner with McBee Associates on the consulting firm’s blog. “How it will be completed, data sources allowed and what will be considered ‘up-to-date’” will all be crucial to HHAs filling this out correctly, Horner notes.

“We need the official guidance to know what they expect,” Krafft tells AAPC. CMS says only that it will issue the OASIS-E1 Guidance Manual “at a later date,” according to its OASIS Date Sets website.

“The question seems clearly worded, but the definition of ‘up to date’ will require agencies to take a closer look at this item and determine how they will obtain and/or confirm this information,” Huff points out. That information-gathering process “likely will need to start at intake,” she expects.

The COVID-19 vaccination data “might be difficult to obtain and verify, but as an addition as a new home health quality measure, agencies need to make sure that they have a solid process in place,” Huff urges.

CMS finalized COVID-19 Vaccine: Percent of Patients/ Residents Who Are Up to Date (Patient/Resident COVID-19 Vaccine) as a new home health quality measure in its 2024 final rule, over much industry protest. The agency also finalized its plan to publicly report that data.

“The COVID-19 Vaccine measure continues CMS’s commitment to promoting the uptake of the COVID-19 vaccine and ensures alignment with current CDC guidance,” the agency said in its final rule fact sheet.

Watch out: “Keeping up with the ‘current’ CDC guidance is going to … be a part of this process, which likely will continue to evolve and require ongoing educations as to what is ‘current,’” Huff tells AAPC. “The devil is always in the details and verifying this information has the potential to be more difficult than it would initially seem to be,” she warns.

The result “will make this item vulnerable to being answered incorrectly, which in turn will impact the agency’s quality measure scoring,” Huff cautions.

Another important change isn’t in the tool itself, but rather which patients it applies to.

In its 2023 home health final rule, CMS mandated a phase-in of OASIS for patients with all payers starting in 2025. During the phase-in period of Jan. 1, 2025 through June 30, 2025, failure to submit the data will not result in a penalty, the agency said (see more details in HHHW by AAPC, Vol. XXXI, No. 39-40).

CMS did retain exceptions for patients under the age of 18 and maternity patients.

“Many agencies are already submitting all OASIS, so that process might already be in place for some organizations,” Huff allows. “But for those that have not been submitting all OASIS, the full submission process will need to be implemented,” she emphasizes.

Other revisions in OASIS-E1 include:

• Deletions. “CMS finalized removal of two OASIS items that are no longer necessary for collection, the M0110 — Episode Timing and M2220 — Therapy Needs items,” the agency notes in its final rule fact sheet.

Those are “both leftovers from PPS,” Krafft notes.

The removals “have been requested for quite some time, since the items were no longer providing value under [the Patient-Driven Groupings Model],” Huff explains. Even though the items “were no longer relevant under the payment model, [they] still required unnecessary ‘clicks’ and responses from clinicians that provided no real value,” she notes.

CMS also noted it “will remove the items for Self Care Discharge Goals (that is, GG0130, Column 2) and Mobility Discharge Goals (that is, GG0170, Column 2),” according to the final rule.

“This coincides with the removal of the quality measure ‘Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function,’” Horner specifies.

That’s “in preparation for the changes to [the Home Health Value-Based Purchasing program],” Krafft observes.

“Those removals are worth a brief ‘Woo Hoo’ celebration,” Huff cheers.

• M2420. In the OASIS-E1 draft, “updates have been made to the language of certain items, including M2420 — Discharge Disposition,” notes Melinda Gaboury with Healthcare Provider Solutions. “The current language stating ‘Formal Assisted Services,’ will be modified to specifically say ‘skilled services from a Medicare Certified HHA,’” Gaboury details in her Monday Minute with Melinda vlog.

“Although the instructions clarified this change, it still caused confusion for some. Therefore, the language will be specifically changed to alleviate any misunderstandings,” Gaboury summarizes.

“The guidance related to the scoring of M2420 changed back in 2020, but the wording of the response choices was never updated to match, creating confusion and inaccurate responses to the item,” Horner explains. “The clarification in the language of the responses aligns with the current guidance and will promote more accurate scoring of the item,” she praises.

• D0150. Changes to this item on Patient Mood Interview (PHQ-2 to 9) will clarify “when to stop the interview after completing D0150A and D0150B and when to continue to ask the remaining 7 D0150 questions,” Megan Bernier with OASIS Answers Inc. says in a post on the consulting firm’s website.

Why the change was needed: “Since the implementation of OASIS-E in 2023, there have been many updates and