Home Health & Hospice Week

Item for COVID vax quality measure is now on deck.

For once, Medicare officials are giving home health agencies plenty of advance notice about a significant change.

On Jan. 2, the Centers for Medicare & Medicaid Services issued the next update to the OASIS assessment instrument. OASIS-E1 will take effect almost a year from now on Jan. 1, 2025, CMS says in its notice.

However: The tool itself is only half the story. CMS has yet to release the updated OASIS Guidance Manual that will give instructions for the new and updated items. “The accompanying OASIS-E1 Manual will be released at a later date,” the agency says on its OASIS Data Sets webpage.

For now, HHAs can familiarize themselves with some of the upcoming changes.

For example: “Added to the instrument is the new COVID-19 Vaccination item which is found in Section O of the instrument and is OASIS item O0350.A,” points out consulting firm OASIS Answers in its blog.

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. Among other things, agencies commented that the measure holds HHAs accountable for things out of their control; that patients can’t remember and report their vaccination status accurately; that the question may cause friction between clinicians and patients; and that the measure hasn’t been tested or validated (see HHHW by AAPC, Vol. XXXII, No. 39-40).

Another change: “The OASIS document needs to be updated to accommodate some changes related to … the end of the temporary suspension of OASIS for non-Medicare/non-Medicaid home health patients and the removal and addition of OASIS items related to measures for the Home Health Quality Reporting Program (HHQRP), payment calculation, and/or Medicare conditions of participation,” the National Association for Home Care & Hospice explains in its member newsletter.

“Beginning in 2025, home health agencies will need to collect OASIS data for all patients regardless of payor source,” NAHC reminds. While other current exemptions will continue, such as those for minors or maternity patients, “a phase-in period is in place for January 1, 2025 through June 30, 2025 in which failure to submit the data will not result in a penalty. Mandatory collection and reporting begin with discharges on or after July 1, 2025,” the trade group reviews.

Additional changes include updates to M2420 — Discharge Disposition and D0150 — Patient Mood Interview, OASIS Answers highlights.

And CMS is removing OASIS items M0110 — Episode Timing, M2220 — Therapy Needs, and GG0130 and GG0170 — Discharge Goal, NAHC details.

Note: The 35-page updated draft is at www.cms.gov/files/document/draftoasis-e1allitemsinstrument-01-02-2024.pdf.