Home Health & Hospice Week

In the Centers for Medicare & Medicaid Services’ April 13 Home Health Open Door Forum, a CMS official noted that the agency will offer OASIS-E guidance and training this summer. That’s despite the fact that CMS is committed to holding off the updated tool’s implementation until after the PHE expires, a CMS spokesperson confirms to AAPC (see HCW by AAPC, Vol. XXX, No. 15).

Starting OASIS-E orientation and training a theoretical 18 months ahead of time may seem like overkill. “In the past, when we have had training months before the implementation of anything, it is forgotten by the implementation date,” laments Julianne Haydel with Haydel Consulting Services in Baton Rouge, Louisiana, and The Coders. “Plus, I have no confidence in CMS not making some changes before then,” Haydel adds.

HHA staff “can’t learn something that won’t go into effect till 2023,” stresses Sharon Litwin with Healthcare Provider Solutions in Nashville, Tennessee. And “agencies can’t prepare during a pandemic. It will be a lot of training [for] OASIS clinicians and they will need to focus on it.”

HHAs’ and their assessment staff ’s plates are full enough during COVID, particularly considering staffing shortages, Parson notes.

Due to these and other issues, “I doubt people will attend [this summer’s] training in large numbers,” predicts Cindy Krafft with Kornetti & Krafft Health Care Solutions.

Still, don’t write off the forthcoming guidance and training altogether. This summer is a good time to begin OASIS-E learning, advises J’non Griffin with Home Health Solutions in Carbon Hill, Alabama. “It will take quite a bit of time to understand all the changes,” Griffin points out.

“With so many competing priorities, it can be easy for agencies to push off training until a little closer to actual implementation time,” acknowledges Angela Huff with BKD in Springfield, Missouri. “However, we would encourage agencies to engage early and take advantage of these training opportunities as soon as possible. With significant changes to the instrument, the more time that your staff has to understand, digest, and prepare for OASIS-E, the smoother the transition will be for the end users.” That, in turn, “should lead to more accurate documentation,” she says.

For optimal OASIS-E implementation, follow this additional advice from the experts:

• Get up to speed on OASIS-E. Under the Biden administration, the Department of Health and Human Services has signaled that the COVID-19 PHE will run at least through the end of 2021. CMS says OASIS-E “will be delayed until January 1^st of the year that is at least 1 full calendar year after the end of the COVID-19 PHE.”

Presuming that the PHE ends some time next year, home health agencies would be looking at a January 2024 implementation date. But considering that the PHE is going longer than first anticipated, observers predict that CMS actually will opt for January 2023 implementation.

HHAs can already check out the draft OASIS-E tool at www.cms.gov/files/document/draft-oasis-e-all-items03122020.pdf and more specific guidance and training will be coming from CMS this summer.

“Agencies should consider having someone participate” in CMS’s education this summer “so they can better understand where we are today with OASIS-E and what we need to start preparing,” Krafft counsels.

• Set a training timeline. HHAs should assess how much training their OASIS staff will require, then determine a schedule for ramp-up. “There will clearly be training needs on the new content,” Krafft agrees.

For January 2023 implementation, assessment staff will “need to train next spring,” Litwin believes. “Then teaching can become widespread in the summer of 2022,” she advises.

• Take some steps now. While large-scale OASIS-E training should wait until 2022, agencies can implement some measures to give themselves a head start on the new tool.

“With the [OASIS-E] delay, agencies are becoming OASIS-complacent,” Krafft worries. “Based on the work we do in both outsourced reviews and auditing, the ‘same old mistakes’ keep happening over and over,” she tells AAPC. Training on OASIS basics can get your assessments in tiptop shape before new requirements hit.

HHAs can also start getting staff familiar with SPADE items gradually leading up to the OASIS-E start date, Parson suggests. “CMS has begun putting out great trainings on various items we will see in OASIS-E, such as the BIMS,” Parson points out. “Every agency should take advantage of any of this training. The modules that CMS has been providing on specific items have been very informative and well done.”

You can find links to the BIMS, CAM, and other training modules at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Skilled-Nursing-Facility-Quality-Reporting-Program/SNF-Quality-Reporting-Program-Training.

• Plan for productivity hit. Training on the new OASIS items will cut into your staff ’s productivity, as will filling out the new tool. “Any time additions to the OASIS occur, there is increased burden for providers,” Huff highlights. That’s particularly true “at the beginning stages of implementation, with education needed for the individual items, including the way the responses are formatted,” she explains.

OASIS-E “will take longer in the beginning because it is new,” Haydel notes. “New stuff will take longer — about five occurrences — until the flow of the assessment becomes known.”

Plus: Going forward, “there will be additional time required for clinicians to assess the items and document the responses that in turn will add time to the overall visit,” Huff says. “With eight items that have multiple selections and discussion required to complete the assessment, it will easily add a few minutes to complete these items even after the clinicians are comfortable with new content,” she expects.

The more comprehensive your assessments have been, the less of a time hit you will take, Haydel predicts. For example, “high risk drugs should be known by the nurse completing the assessment,” she points out. They will be covered in the incoming item N0415 (High-Risk Drug Classes).