Home Health & Hospice Week

CMS wants you to enter different dates in M0090 for end-of-year window.

The transition to the prospective payment system refinements just got more confusing.

But home health agencies are glad to have official guidance from the Centers for Medicare & Medicaid Services about how to complete OASIS in the five-day window before PPS takes effect Jan. 1.

In a new set of questions and answers, CMS explains how to fill out assessments to result in correct HIPPS codes for episodes. When an episode begins in 2007 it needs a HIPPS code from the current PPS, while an episode starting in 2008 needs a refinements HIPPS code.

"The guidance offers clarification about assessment timing and completion dates that is critical for assignment of correct case-mix weights," the National Association for Home Care & Hospice stresses. The right case-mix assignment will ensure "accurate payment during transition to the reformed home health prospective payment system," NAHC says.

"A lot of agencies will have those complications," consultant Melinda Gaboury with Healthcare Provider Solutions in Nashville, TN says of the Q&A examples. "They will need to try to figure out what to do"--and the Q&As should help them with that.

CMS offers these three situations when clinicians will have to put different or "artificial" dates in M0090 to obtain the correct HIPPS code: Scenario 1: You complete a recertification assessment during the last five days of 2007 and that assessment must provide the HIPPS code for an episode that begins before Jan. 1.

The problem: The new version of OASIS that supports PPS changes and the grouper software will use recert OASIS data from Dec. 27 to Dec. 31 to generate a HIPPS code under PPS refinements, CMS explains in the Q&A. "To allow for the 5-day recertification window for episodes of continuous care that begin on 1/1/2008 through 1/5/2008, the new OASIS data specifications are effective for OASIS RFAs 04 or 05 with completion dates (M0090) of 12/27/2007 or later."

The solution: So, agencies must use an "artificial" date of Dec. 26 in M0090 to obtain a HIPPS code that will pay correctly for the episode that begins before Jan. 1, CMS instructs. Staffers should enter a date of 12/26/2007 in M0090 even though the actual assessment date was between Dec. 27 and Dec. 31.

The requirements: To qualify for this waiver, the episode must be a Reason for Assessment (RFA) of 04 (recert) or 05 (other followup); an assessment completion date between Dec. 27 and Dec. 31; and a need for the assessment to produce a HIPPS code for a 2007 episode.

The M0090 waiver is "a one-time exception, to facilitate the transition to the revised HH PPS case-mix system and save HHAs the burden of completing two separate assessments in these instances," [...]