Home Health & Hospice Week

Watch for draft of revamped assessment tool in early summer.

If you’re under pressure from staffing shortages, vaccination mandates, and other COVID-related burdens, you’d better figure out how to implement OASIS-E in January 2023 anyway. That’s because Medicare has finalized that date for implementation in the 2022 home health final rule.

Reminder: Last year, the Centers for Medicare & Medicaid Services bumped OASIS-E from its Jan. 1, 2021 start date to give agencies a break during the COVID-19 Public Health Emergency. “HHAs will be required to use OASIS-E … beginning with discharges and transfers on January 1st of the year that is at least 1 full calendar year after the end of the COVID-19 PHE,” CMS said in an interim final rule published in the May 8, 2020 Federal Register. When CMS began making noises about OASIS-E training this past spring, a CMS representative assured AAPC in April that the agency planned to stick to that timeline (see HCW by AAPC, Vol. XXX, No. 15).

But in the 2022 proposed rule, CMS floated January 2023 as the new OASIS-E implementation date, and now it has finalized the date in the final rule.

Many commenters said they didn’t have the bandwidth to take on a new assessment tool overhaul, especially if CMS didn’t remove items to make up for the added ones.

CMS isn’t buying that assertion. “Based on a review of the current impacts of the PHE on HHAs nationally, we believe HHAs are well-positioned to successfully implement OASIS-E beginning January 1, 2023,” the final rule insists.

OASIS-E is important, CMS stresses. “The need for the Standardized Patient Assessment Data Elements and Transfer of Health data have shown to be even more pressing with issues of inequities that the COVID-19 PHE laid bare,” the rule says. “This data that includes addressing SDOH provides information that is expected to improve quality of care for all,” so the revised compliance date “reflect[s] this balance,” it says.

Bottom line: “We are finalizing that HHAs will begin collecting data on the two TOH measures beginning with discharges and transfers on January 1, 2023 on the OASIS-E. We are also finalizing that HHAs will collect data on the six categories of Standardized Patient Assessment Data Elements on the OASIS-E, with the start of care, resumption of care, and discharges (except for the hearing, vision, race, and ethnicity Standardized Patient Assessment Data Elements, which would be collected at the start of care only) beginning on January 1, 2023.”

CMS tries to assure HHAs that they will help them in the OASIS-E implementation effort. “CMS will provide the training and education for HHAs to be prepared for this implementation,” it vows in the final rule. In addition, CMS will “release a draft of the updated version of the OASIS instrument, OASIS-E, in early 2022.”

But CMS punts on removing other items from OASIS to make way for the things. CMS “will continue to evaluate and consider any burden associated with changes to the OASIS,” it says vaguely in response to comments “to consider ways to mitigate the burden of reporting additional OASIS–E items,” according to the final rule.

Between OASIS-E and Home Health Value-Based Purchasing implementation, both in January 2023, HHAs will be doing a lot of education next year, notes Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee.

Note: See draft OASIS-E data specs at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/DataSpecifications in the “Downloads” section.