Home Health & Hospice Week

Plan your training schedule for 2016.

Home health agencies who want to prepare for the next version of OASIS will have to wait for the full story.

Reminder: On Dec. 22, the Centers for Medicare & Medicaid Services issued a new OASIS-C2 assessment tool for January 2017 implementation. The new form aimed at IMPACT Act compliance introduces three new items, modifies and renumbers wound and medication items, changes the lookback period for five items, and includes formatting changes throughout the document (see Eli’s HCW, Vol. XXV, No. 1 for details about the changes).

But the tool CMS has released provides only some of the information necessary for OASIS-C2 completion. CMS plans to issue “specific guidance … in the OASIS guidance manual, which we intend to release next summer,” a CMS official tells Eli.

For example: OASIS-C2 contains new item M1060 (Height and Weight), which will ask for height in inches and weight in pounds. When CMS proposed this item in conjunction with the 2016 prospective payment system rule, HHAs complained that the measurements would be virtually impossible to obtain in some cases. But in the OASIS-C2 form released last month, CMS appeared to leave the item basically unchanged from the draft.

Clarification: The changes will be in the forthcoming OASIS manual, the CMS source reassures.

“Providers will have the opportunity to enter a dash on this item in instances where height and weight cannot be obtained,” the staffer tells Eli. The manual will contain “specific guidance on this item and its allowable responses.” In the meantime, more information is in the OASIS-C2 data specs at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/OASIS/DataSpecifications.html, the official points out.

Sketch Out Your Training Timeline

Giving your clinicians a heads up now that a new OASIS form is on the way may be a good idea, advises consultant Cindy Krafft with Kornetti & Krafft Health Care Solutions.

Agencies can “at least review the changes and new items in the OASIS-C2 form within the next few weeks,” offers nurse Judy Adams with Adams Home Care Consulting in Asheville, N.C. But Krafft recommends holding off on specific item training until CMS issues its manual. This will “limit the chance of error in providing the instruction,” notes Krafft, who is a physical therapist.

“Training would be best after the manual is available,” Adams agrees. “The current draft does not really give much in the way of guidance.”

Nurse Lynda Laff with Laff Associates believes agencies can even wait until the fall to get into specific review and training for OASIS-C2, she says.

However: Now is a great time to brush up on the basics underlying the items that will be changing, Krafft counsels. “A revisit of all the medication items should occur ASAP if my audits are any indication,” Krafft tells Eli.

Common mistake: “I consistently read OASIS records where meds are missing from the home/have not been picked up yet and ‘no problems’ is selected,” Krafft relates.

On the management level, you can’t just ignore OASIS-C2 until close to implementation, however. You should work on issues that support the new and revised items, such as generating a standardized policy and procedure for collecting weight for M1060, and working out a process for setting discharge goals for GG0170c, experts advise.

Software vendors are the ones who will be taking on the brunt of the extra work due to OASISC2, Laff predicts. “The constant incremental changes are a nightmare for them,” Laff notes. “It means that they are being required to reconfigure and re-program data constantly,” often with insufficient time from the data specs’ release.

Note: A link to the OASIS-C2 item set is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/OASIS-Data-Sets.html.