Home Health & Hospice Week

OASIS:

OASIS-Based Denials On The Horizon

Get your OASIS submission ducks in a row before your reimbursement depends on it.

Think you have a handle on the OASIS-claims matching requirement? You may need to think again.

Be aware that the matching requirement’s implementation is fairly non-threatening because for now, “if an OASIS is not in the system, the claim will pay as it was filed,” points out Melinda Gaboury with Healthcare Provider Solutions in Nashville.

But “submission of an OASIS assessment for all HH episodes of care is a condition of payment,” the Centers for Medicare & Medicaid Services stresses in a recently updated MLN Matters article on the topic. “CMS plans to use the claims matching process to enforce this condition of payment in the earliest available Medicare systems release. At that time, Medicare will deny claims when a corresponding assessment is past due in the QIES but is not found in that system.”

Warning: “Once the system is updated to deny claims if the OASIS is not in the system, there is going to be a lot of agencies in deep water,” Gaboury expects.

Many agencies will be surprised by how many of their claims are actually processing without a matching OASIS in the system yet, believes M. Aaron Little with BKD in Springfield, Mo. That “can occur for a variety of reasons,” he says.

As CMS notes in the MLN Matters article, the agency has yet to set a date for implementation of the rejection edits. That date likely “will depend on how well the processes and edits work in the early days,” Little predicts.

Tip: “Assess processes to ensure that all OASIS data is routinely being submitted — and accepted — prior to claims submission to prevent potential problems” when these edits take effect, Little counsels.

At least once the denial edits are in place, agencies aren’t likely to have to deal with claims denied for not matching the OASIS, Gaboury anticipates. As with the edits taking effect April 1, she expects “they will continue to pay based on the HIPPS code from OASIS if it doesn’t match the claim” — not deny. Most likely, only claims missing OASIS altogether will face denials.

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