Home Health & Hospice Week

Major pressure ulcer changes may throw your OASIS staff — and your payments — for a loop.

Along with their holiday bonuses, you can put one more thing in your employees’ stockings — OASIS-C2 preparation.

You should already have given your OASIS completing staff an overview on the new tool that takes effect Jan. 1 and that the Centers for Medicare & Medicaid Services released a year ago. But with face-to-face compliance, Pre-Claim Review, stepped-up medical review, and a host of other priorities taking your attention in 2016, you may not have placed the emphasis the updated assessment tool deserves.

You still have a couple of weeks to rectify the situation and bolster staff’s OASIS-C2 knowledge and practices.

First things first: Number-one on home health agencies’ prep list in these last weeks of 2016 should be understanding and training staff on new pressure ulcer guidance, advises OASIS expert Lisa Selman-Holman with Selman-Holman & Associates in Denton, Texas.

Consult item-by-item guidance in Chapter 3 of the OASIS-C2 Guidance Manual to train your employees on new items and procedures, suggests consultant Anna Doyle.

OASIS-C2 is adding three items based on the IMPACT Act — M1028 Active Diagnoses, M1060 Height and Weight, and GG0170c Mobility. But the pressure ulcer changes are arguably the biggest difference between the old and new tool.

“The pressure ulcer world turns upside-down January 1, 2017,” emphasizes consultant Beth Noyce on her blog. “Don’t apply old OASIS direction to OASIS-C2. The rules are changed,” Noyce warns.

Don’t miss: “OASIS-C2 pressure ulcer documentation guidance repeals and replaces much of the OASIS-C1/ICD-10 guidance,” Noyce tells Eli.

The Texas OASIS Help Desk reviewed M1306 guidance for OASIS-C2 in its September newsletter. “Stage 3 and 4 (full thickness) pressure ulcers heal through a process of granulation, contraction and reepithelialization. Once the pressure ulcer has fully granulated and the wound surface is completely covered with new epithelial tissue, the wound is considered closed, and will continue to remodel and increase in tensile strength,” it explains. “For the purposes of scoring the OASIS, the wound is considered healed at this point, and should no longer be reported as an unhealed pressure ulcer.” That guidance also applies to M1307, M1311 and M1313, notes Judy Adams with Adams Home Care Consulting in Durham, N.C.

Big difference: “The older guidance for eons has allowed closed stage 3 and 4 pressure ulcers to be considered unhealed,” Adams points out. Now that’s about to change. In other words, “healed pressure ulcers are not captured in OASIS items,” Noyce stresses.

Watch out: That huge revision will have a big impact on payment, Adams warns. Not counting closed stage 3 and 4 pressure ulcers as unhealed can shave “20-plus points in the clinical dimension that would bring an agency to the highest clinical dimension score,” she explains. Of all the changes in OASIS-C2, “the wound one concerns me the most,” says Cindy Krafft with Kornetti & Krafft Health Care Solutions. “Lots of clinicians struggle with changed guidance, especially when it contradicts what many have been told to do for years.”

Tip: “The guidance for M1306 also indicates home health agencies may adopt the [National Pressure Ulcer Advisory Panel] guidelines in their clinical practice and documentation,” the Texas OASIS Help Desk notes. “However, since CMS has adapted the NPUAP guidelines for OASIS purposes, the definitions do not perfectly align with each stage as described by NPUAP. When discrepancies exist between the NPUAP definitions and the OASIS scoring instructions provided in the OASIS Guidance Manual and CMS Q&As, providers should rely on the CMS OASIS instructions.” (See a link to the new NPUAP guidance in story, p. 346.)

Beware Other Changes

And guidance for item M1313 (M1309 in the current tool) has changed, points out Healthcare Provider Solutions in an overview of the changes between OASIS-C1 and OASIS-C2. The changed instructions for a-c tell agencies to “indicate the number of current pressure ulcers that were not present or were at a lesser stage at the most recent SOC/ROC,” HPS emphasizes.

Heads up:Watch out for the “allowed diagnoses in M1028 related to peripheral arterial disease, PVD and diabetes that will impact risk adjustment for pressure ulcers,”Adams cautions.

To comply with the new items on height and weight in M1060, make sure your staff have scales and measuring tapes, Selman-Holman tells Eli.

Do this: CMS reminds agencies in the OASIS-C2 Guidance Manual that staff should be measuring patients all in the same way, according to agency policy. That means your agency needs to have such a policy, and you must train your employees on it.

OASIS-C2 will allow you to put dashes in the height and weight spaces for M1060. But train your clinicians to avoid using dashes when at all possible to avoid problems ranging from possible survey citations to claims denials.

“CMS expects dash use to be a rare occurrence,” the agency says in the OASIS-C2 Guidance Manual. HHAs would usually use dashes only in the event of an unexpected transfer or death, CMS says.

Another important change will be to the look-back period, notes Ann Giles with PPS Plus in a blog post for the software company. The C-1 wording, “at the time of or since the most recent OASIS,” will be updated to “at the time of, or at any time since the most recent SOC/ROC” for M1501, M1511, M2005, M2016, M2301 and M2401, Giles says.

Other changes taking effect in OASIS-C2 include formatting changes to convert multiple check boxes to a single box for data entry and changing Roman numerals to Arabic numerals in wound staging questions, Doyle tells Eli.

OASIS-C2 also modifies medication items. “The new items catch whether clinicians contact the patient's physician about every clinically significant medication issue and get a physician's response to resolve each issue within one calendar day,” Noyce summarizes. (See more details of OASIS-C2 changes in HCW, Vol. XXV, No. 1).

Take action: HHAs need to reach consensus on what is a medication “issue” for revised items M2001, M2003 and M2005, Krafft advises.