Home Health & Hospice Week

Clarification could affect your Care Compare star rating.

If you want to make your Care Compare scores the best they can be, your assessment staff need to understand the ins and outs of OASIS questions.

In its latest OASIS Quarterly Question-and-Answer set released July 20, the Centers for Medicare & Medicaid Services clears up a question on M0104 (Date of Referral).

Question: “We received a general home care order to evaluate for home care needs for a patient after she experienced recent falls. At the time of the referral we don’t know what her care needs will be for home care. Would that general home care order constitute a valid referral for the purposes of determining M0104 - Date of Referral?” one of the 13 new Q&As says.

Why it matters: CMS uses the data from M0104 in the Timely Initiation of Care process measure reported on Care Compare as “How often the home health team began their patients’ care in a timely manner.” That score is rolled up into home health agencies’ Quality of Patient Care star ratings on the website.

The Timely Initiation of Care measure calculates the “percentage of home health quality episodes in which the start or resumption of care date was on the physician-ordered SOC/ROC date (if provided), [or] otherwise was within 2 days of the referral date or inpatient discharge date, whichever is later,” CMS explains in its OASIS-D1 Home Health Process Measures Table at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Home-Health-Quality-Measures (scroll down to the “Downloads” section).

Answer: “M0104 - Date of Referral specifies the referral date, which is the most recent date that verbal, written, or electronic authorization to begin or resume home care was received by the home health agency. A valid referral is considered to have been received when the agency has received adequate information about a patient (name, address/ contact info, and diagnosis and/or general home care needs) to initiate patient assessment and the agency has ensured that the referring physician, or another physician or allowed non-physician practitioner will provide the plan of care and ongoing orders,” CMS answers. “If a general order to ‘Evaluate for Home Care services’ (no discipline(s) specified) is received from a physician who will be following the patient, this constitutes a valid order,” the Q&A confirms.

However, “if Start of Care or Resumption of Care is delayed due to the patient’s condition or physician request (for example, extended hospitalization), then the date the agency received updated/revised referral information for home care services to begin would be considered the date of referral,” CMS elaborates in its OASIS-D Guidance Manual. “This does not refer to calls or documentation from others such as assisted living facility staff or family who contact the agency to prepare the agency for possible admission.”

For Medicare Advantage and other insurance patients, “the date authorization was received from the patient’s payer is NOT the date of the referral (for example, the date the Medicare Advantage case manager authorized service is not considered a referral date),” CMS emphasizes in the manual’s response-specific instructions.

Tip: To optimize the timely initiation of care measure, HHA clinicians should contact the patient and/or family the night before to arrange a time for the initial/SOC visit, advised consultant Teresa Northcutt with Selman Holman & Associates in a previous educational session for the Kansas Home Care Association. They should “document any problems with visit scheduling and communicate to office staff,” Northcutt said.

If staff are unable to schedule a visit, the agency should identify the reason and communicate with the ordering physician to obtain an order to move the SOC date, Northcutt recommended.

The national average for the timely initiation measure is 95.7 percent, according to Care Compare. HHAs should strive to meet or exceed that benchmark, experts urge.

Note: A link to the five-page Q&A set is at https://qtso.cms.gov/reference-and-manuals/oasis-quarterly-q. The OASIS-D Guidance Manual is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/OASIS-D-Guidance-Manual-final.pdf.