Home Health & Hospice Week

Get ready for a whole new wave of patient data collection with OASIS-C.

The new OASIS-C form will contain a lot of changes your clinicians will have to get used to, but the fact that many of them will be welcome ones could make the transition easier.

The Centers for Medicare & Medicaid Services issued its new OASIS-C form and is requesting comments by Jan. 13 (see Eli’s HCW, Vol. XVII, No. 41, p. 322). After taking industry comments into account, CMS will issue a final form and instructions next year for January 2010 implementation, CMS officials indicate.

By far, the biggest change in the newest incarnation of the form will be the additional process measures on a variety of topics, says Chi-cago-based regulatory consultant Rebecca Fried-man Zuber. The new process-based M0 items cover:

• care provision timeliness (M0102 and M0104);

• physician notification (M1038);

• immunizations (M1040, M1045, M1050, and M1055);

• risk assessments, care planning, and interventions for pain (M1242, M1244, and M1246), depression (M1730, M1732, M1734, and M1736), falls (M1930, M1940, and M1945), and pressure ulcers (M1300, M1302, M1304, and M1306);

• interventions for diabetes (M1360 and M1365), heart failure (M1500 and M1510), and pressure ulcers (M1326 and M1328);

• and drug reviews and teaching (M2000, M2002, M2004, M2010, and M2015).

"There will certainly need to be considerable re-education for clinicians on the OASIS form and the individual questions," predicts Judy Adams, consultant with LarsonAllen based in Charlotte, N.C. (For tips on how to begin preparing for OASIS-C, see a future issue of Eli’s Home Care Week.)

CMS Claims HHAs Will See No Added Burden

The process measures will be a big change for clinicians, acknowledges Ann Rambusch with Rambusch3 Consulting in Round Rock, Texas. But after staffers get used to the revisions, Rambusch believes they will prefer the new form. "The new format makes more sense, and in the long run clinicians will like it," Rambusch tells Eli.

How much more work? The amount of burden the new form, and particularly the new process measures, will place on your agency will depend on your current practices, Adams says. If you’re already performing screenings, conducting interventions for chronic conditions, and performing drug reviews and teaching, the new form will merely require you to record those items.

But if you haven’t been taking all of those steps yet, you’ll have a lot of clinical processes to get into place before the new form hits about a year from now, experts warn.

Using the existing OASIS instrument is a "small burden," CMS claims in supporting documentation for the new OASIS-C form. And using the new form won’t be any more work after training is completed, the agency contends. "Clinicians who participated in the field testing reported that the OASIS-C took about the same time to complete as the OASIS-B1," CMS says.

Comparison: At start of care, the OASIS-C could require clinicians to answer 105 M0 items, while the current B1 form requires only 76 items, CMS explains in the supporting documentation. Resumption of care and transfer to inpatient assessments could also see a big difference -- 61 versus 90 items and 11 versus 26 items, respectively. On the other hand, follow-up/recerts and discharge assessments would remain about the same -- 30 versus 32 items and 75 versus 74 items.

But all those new items won’t always apply. "Some patients will not have any of the issues that CMS is focusing on -- heart disease, depression, fall risk, [or] pressure ulcer risk," Rambusch points out. "Their OASIS will be shorter."

Focus On These Positive OASIS-C Changes

Staffers who are grumpy about learning the new form may be pleased to see many changes they’ll like, such as eliminating the "prior" category on activities of daily living in M0640-M0770, which will become M1800-M1920, Adams points out.

They might also like CMS’s elimination of M0730-M0760 on transportation, laundry, housekeeping, and shopping and the addition of two questions about caregiver assistance (M2110 and M2120), Adams expects.

These revisions "should be welcomed by clinicians as major improvements and perhaps improve their acceptance of the OASIS as useful in providing clinical care," Adams says.

Other changes to the form include:

• adding a list of inpatient procedures with associated ICD codes (M1012);

• replacing prognosis and life expectancy items (M0260, M0270, and M0280) with items on "frailty indicators" (M1032) and a "stability prognosis" (M1034);

• dropping items on the patient’s residence and caregivers (M0300-M0380) and adding a single question on that topic (M1100);

• dropping items on intractable pain (M0430), caregiver management of equipment (M0820), post-discharge assistance (M0880), and surgical wound items (M0484 and M0486);

• adding items on understanding verbal content (M1220), mobility (M1880), and self-care (M1890); and

• dropping the item on management of inhalant/mist medications (M0790) and adding a broader medication management question (M2040).

Hidden hurdle: Don’t forget about the confusion that simply changing M0 item numbers will cause, Friedman Zuber adds. "It seems like a small thing, but the new numbers are going to be tough to adjust to," she tells Eli. v