Home Health & Hospice Week

Expert payment diagnoses to become much more complex.

Get ready for your OASIS instrument to look very different in some places.

The Centers for Medicare & Medicaid Services outlines plans to delete, modify and add items to the OASIS assessment in its May 4 request that the Office of Management and Budget approve extending use of the OASIS data set beyond the Aug. 31 expiration date.

Many parts of the OASIS assessment will stay the same under the prospective payment system refinements, including the time points for assessment, the absence of a requirement for locking data and the suspension of OASIS data collection for non-Medicare/non-Medicaid patients, CMS says.

Expect OASIS form overhaul: No matter what PPS changes CMS makes in response to industry comments, the OASIS assessment form will require changes for both initial and follow-up assessments.

Consider the following five major changes:

1. M0175 errors will no longer cost you money. Data show M0175 (From which of the following inpatient facilities was the patient discharged during the past 14 days) lacked predictive value for the case mix model, CMS explains. And the administrative headaches associated with M0175 affected agencies and intermediaries alike. So CMS proposes removing this M0 item from recertification and other follow-up assessments because it will no longer be part of the case mix calculation under the PPS update. CMS also plans to delete the reference to the follow-up assessment in the "NA" response in M0175.

"Although the pressure will be off case mix accuracy in answering M0175, this item will continue to be important for its impact on risk adjustment," notes consultant Judy Adams with Charlotte, NC-based LarsonAllen.

Prior location of the patient has little, if any, impact on care planning, Adams believes, and removing M0175 from OASIS would have been a good thing.

Waiting game: But CMS plans to make overall OASIS form changes in 2009, a CMS staffer said in the May 23 home health Open Door Forum. Agencies will just have to wait until then for the improvements.

2. M0110 will become part of the OASIS assessment. M0110 (Episode timing: Is the Medicare home health payment episode for which this assessment will define a case mix group an "early" episode or a "later" episode in the patient's current sequence of adjacent Medicare home health payment episodes) will be a new factor in the case mix calculation under the proposed PPS update.

The agency will choose from the options "early" for single episodes or the first two episodes in a sequence of adjacent episodes, or "later" for the third or later episodes, CMS explains.

Fine print: For these definitions, episodes don't have to directly follow one another but can be "adjacent"--spaced apart up to 60 days, CMS says. And the definitions apply whether the subsequent or adjacent episodes take place at one home health agency or across multiple HHAs.

"Agencies are really going to have to train their staff to get this answered accurately and develop a process to efficiently gather this information," consultant Mark Sharp with Springfield, MO-based BKD tells Eli. Agencies will have to be very careful in capturing the accurate episode count for those patients who have transferred from another agency, adding some administrative burden much like M0175, he adds.

In fact, one caller to the Open Door Forum expressed frustration that her agency might see M0110 adjustments much like the big-league M0175 takebacks agencies have experienced this year.

"We're working to avoid that situation," CMS promised forum attendees.

3. M0230 and M0240 will experience format and instruction changes. Updates regarding diagnosis coding in M0230 and M0240 (Diagnoses and severity index) are among the most visually different in the proposed OASIS assessment changes.

A four-column table--shared with the new M0246 item--organizes your answers:

• The first column contains the description of the primary and secondary diagnoses.
• The second column has space for the related ICD-9 code and the severity rating for each condition.
• The third column, which is optional, has a space for a numeric ICD-9 code if the code in the second column is a V code reported in the place of a case mix diagnosis.
• The fourth column, also optional, includes a space for a numeric code if a V code in column two replaced a case mix code and is part of a multiple code, such as a manifestation code.

(For specifics on how diagnosis coding will change, see Eli's HCW, Vol. XVI, No. 19).

4. M0246 replaces M0245. The addition of secondary diagnosis codes to the case mix system means the OASIS form must allow for reporting situations in which a V code replaces a case mix code in secondary diagnoses as well as in primary diagnoses, CMS explains. The current OASIS item M0245 allows that option only for the primary diagnosis, CMS adds.

"This item certainly adds to the complexity of home care diagnosis coding," says coding expert Lisa Selman-Holman with Denton, TX-based Selman-Holman & Associates.

5. M0826 on therapy replaces M0825. If you thought answering "yes" or "no" to M0825 (Therapy need) was complicated, wait until you see the new item.

M0826 (Therapy need: In the home health plan of care for the Medicare payment episode for which this assessment will define a case mix group, what is the indicated need for therapy visits [total of reasonable and necessary physical, occupational, and speech-language pathology visits combined]?) leaves you a three-digit space to enter the number of visits expected and asks you to enter "000" if no therapy visits are indicated.

Upside: The proposed rule allows intermediaries to correct therapy projections and payment up or down at the episode's end. Currently, the claims processing system only automatically adjusts therapy numbers down. v

Note: The proposed changes to the OASIS data set are at www.cms.hhs.gov/PaperworkReductionActof1995/PRAL/list.asp. Agencies have 30 days from the May 4 publishing date to comment on the changes.