Home Health & Hospice Week

From lifting OASIS matching edits to prioritizing in-home workers for PPE, help is falling short.

While home health and hospice agencies appreciate the many waivers from Medicare, extra funding through multiple sources, and other flexibilities instituted to help them fight COVID-19, there’s a lot more lawmakers and regulators can do to help.

For example: In one of its 1135 waivers for home health, the Centers for Medicare & Medicaid Services has waived the 30-day deadline for OASIS data submission.“HHAs are expected to complete the comprehensive assessment within 30 days and delayed submission is permitted,” CMS explains in its regulatory flexibilities document for HHAs.

But a caller in CMS’ April 14 COVID-19 call for HHAs and hospices asked whether the requirement for every home health claim to have a matching OASIS record would also be waived.CMS has not granted such a waiver, an official responded in the call. Because of system requirements, HHAs must submit an OASIS assessment for every Medicare claim. If a claim has no matching OASIS record, an edit will return the claim to provider (RTP).

Without waiving the OASIS matching requirement, the delayed timeline for OASIS submission doesn’t do much good, experts say.“The OASIS extension takes some of the pressure off clinically to complete it, so that’s a good thing,” acknowledges reimbursement expert M. Aaron Little with BKD in Springfield, Missouri.“But since [the OASIS record] still has to be transmitted before the claim is billed, in the short term it doesn’t offer substantial relief as it pertains to the billing process,” Little concludes.

Allowing HHAs to complete an abbreviated OASIS form that contains just the payment items could also be a way to lift burden, agencies have suggested. But that’s not an option either, the CMS official stated in the call. While that’s the kind of relief CMS could provide, it’s not doing so for this public health emergency, the staffer said.

Other moves that could help HHAs cope with the pandemic, according to the National Association for Home Care & Hospice, include:

• Prioritizing home care and hospice workers for personal protective equipment (PPE);
• Direct reimbursement for telehealth and telemedicine visits, such as that provided to physicians; and
• Improved home infusion coverage and reimbursement.

Among changes that would help hospices, according to the National Hospice and Palliative Care Organization, are:

• A reimbursement boost to cover growing costs of staffing, telehealth, and PPE.“A gown that was $0.13 earlier this year is now over $1.00,” emphasizes the NHPCO’s Judi Lund Person.
• Flexibilities with eligibility for higher levels of care, including allowing caregiver illness as a reason for continuous home care (CHC) and reasons other than acute symptom management for general inpatient care (GIP).