Home Health & Hospice Week

Stay tuned for final form.

If you reviewed the new OASIS-C2 form when Medicare issued it last December, there’s nothing new in a recent posting of the form by the Centers for Medicare & Medicaid Services. But you can give CMS a piece of your mind on the new tool.

No joke: CMS posted the tool on its website and invited comments on it in an April 1 Federal Register notice (see Eli’s HCW, Vol. XXV, No. 14). CMS is taking comments on the form that contains three new items until May 31.

CMS maintains “that the OASIS-C2 (v2.20.0) Data Set is still in draft form and is still in the 60-day public comment period,” notes Anna Doyle with Delta Health Technologies. CMS indicates “some modifications may be made to the items in response to the public comment feedback, which is also true for the Data Submission Specifications,” Doyle notes.

However: Industry experts would be surprised to see any substantive changes to the new data set. “Since the comment period is now set, it makes me think that no further changes are waiting in the wings,” shares nurse consultant Judy Adams with Adams Home Care Consulting in Durham, N.C.

“My instinct tells me that there will be no further changes,” Doyle agrees. That’s because “the major changes are in the format now that is designed to move home care into a data collection process that will ‘harmonize’ information across the health care continuum.”

Most of the changes to OASIS, including three new items (M1028 Active Diagnoses, M1060 Height and Weight, and GG0170c Mobility), are due to IMPACT Act conformity, Adams notes.

Stay tuned: “Of course, with CMS there is always the possibility of more changes,” Adams says. CMS indicates it plans to finalize the form and data specs in August, Doyle relates.

Tackle These Changes

The OASIS-C2 additions “will likely be a challenge for clinicians for a while,” Doyle acknowledges. “But the reality is that these are items that are going to be very important with the data collection CMS is looking for in the [Value-Based Purchasing] implementation.”

For example: M1028 will ask clinicians to check all that apply with two options — Peripheral Vascular Disease and Diabetes Mellitus. “These two diagnoses, PVD and DM, both hugely impact cost of care,” Doyle notes.

M1060: Many agencies spoke out against including height and weight in OASIS in comments on the proposal (see Eli’s HCW, Vol. XXIV, No. 38).

But CMS finalized the requirement anyway. “Clinicians will not like this,” Doyle admits. But they “should always have been focusing on height and weight, as weight loss is an indicator of decline and fragility.”

CMS has told Eli it will include an opt-out procedure for M1060, but hasn’t yet said whether there are potential penalties for skipping the item.

GG0170c: The new item on Mobility may be the most confusing for staff, due to its unfamiliar format. Unlike other “M” items, it introduces a whole new section to OASIS — “GG: Functional Abilities and Goals.”

This item “is nearly straight out of the Care Tool,” Doyle points out. “I do believe CMS will give agencies some leeway with accuracy of this item before it is utilized as an actual measure of predicting patient functional ability,” she predicts.

Note: See the link to the data set in the “Downloads” section at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/OASIS-Data-Sets.html.