Home Health & Hospice Week

CMS explains what the new HH CoPs require — and what they don’t.

Home health agencies have had a wide variety of new Home Health Condition of Participationrelated duties since the requirements took effect in January. But tighter OASIS timing for Resumption of Care assessments isn’t one of them, recent clarifications from Medicare indicate.

Question: “The new HH CoPs state that the comprehensive assessment (including OASIS) must be updated within 48 hours of the patient’s return to the home from a hospital admission of 24 hours or more for any reason other than diagnostic tests, or on physician-ordered resumption date,” an HHA asks in the latest set of quarterly OASIS Q&As that the Centers for Medicare & Medicaid Services issued last month. “I understand that I must provide the ROC visit on the physician ordered ROC date, but do I need to also complete the entire ROC assessment on that date? Or do I have 48 hours from the physicianordered ROC date to complete the assessment?”

Answer: “When the physician specifies a date that home care services must resume (a physicianordered Resumption of Care date), the agency is expected to conduct the ROC visit on that date,” CMS responds on the Q&As. “The agency has up to 2 calendar days from the ROC date (M0032) to complete the ROC assessment document (M0090). For example, if the patient is discharged from the hospital on September 1, and the physician orders home care to resume on September 4, the M0102 - Date of Physician-ordered Resumption of Care date is 09-04-XXXX, the M0032 Resumption of Care date is 0904-XXXX, and the M0090 Date Assessment Completed can be anytime on or between 09-04-XXXX and 09-06-XXXX.”

CMS addresses this issue in the OASIS-D Guidance Manual errata it released Aug. 6 as well.

Old language: In the section on time points, the manual CMS released July 2 said, “Aphysicianordered resumption of care (ROC) must be conducted on or within 2 calendar days of the physicianordered ROC date.”

New language: The errata changes the language to “A physician-ordered resumption of care (ROC) visit must be conducted on the physician-ordered ROC date.”

CMS made the correction “to accurately reflect revised Condition of Participation related to physician-ordered ROC date,” the agency notes in its errata document.

“I was happy that CMS further clarified the time frames involved with ROCs,” notes OASIS expert Sherri Parson with Quality in Real Time in Floral Park, New York. It’s important to understand that the assessment deadline “remains two days from an inpatient discharge or the specified day ordered by the physician for the ROC,” Parson tells Eli.

Note: The OASIS Q&As are at https://qtso.cms.gov/download/hha/CMS_OAI_2nd_Qtr_2018_QAs_July_2018_FINAL_508.pdf. The errata document, which contains other changes as well, is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/OASIS-D-Guidance-Manual-Errata-08-06-2018.pdf.