Home Health & Hospice Week

Setting your implementation schedule is still a bit tricky.

Just when you were feeling comfortable with the current version of OASIS, get ready for a new one.

As promised in the 2018 Home Health Prospective Payment System final rule issued last November, the Centers for Medicare & Medicaid Services is gearing up to implement a significantly changed OASIS form on Jan. 1, 2019. In fact, CMS has deemed the changes important enough to give the coming iteration of the assessment tool a new name - OASIS-D.

In the March 12 Federal Register, CMS notes that "the OASIS-D is being modified to: Include changes pursuant to the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act); accommodate data element removals to reduce burden; and improve formatting throughout the document." OASIS-D will replace the current OASIS-C2 form that took effect in January 2017.

What to expect: CMS outlined the changes it's planning in the final rule and supporting documents (see Eli's HCW, Vol. XXVI, No. 42). Currently, there's only one item HHAs collection in Section GG: Functional Abilities and Goals - GG0170C Mobility.

In 2019, CMS will add three GG Section items, CMS explains in a 2019 OASIS Change Table on its OASIS website: GG0100 Prior Functioning: Everyday Activities; GG0110 Prior Device Use; and GG0130 Self-Care.

CMS will also add two items in Section J: Health Conditions: J1800. Any Falls Since SOC/ROC, whichever is more recent; and J1900. Number of Falls since SOC/ROC, whichever is more recent. All but one of the five GG and J items are brand new. GG0100 is converting over from the current M1900: Prior Function.

Plus: CMS will remove 33 OASIS items to reduce burden (see box, p. 83).

CMS claims eliminating the items should counterbalance the added burden of the new IMPACT Act-driven elements. But industry experts say the changes will still be burdensome and costly.

It could have been worse, however. "The OASIS-D is likely to be sparse compared to what CMS had proposed in the 2018 HHPPS rate update rule," notes Mary Carr with the National Association for Home Care & Hospice. In the HH PPS 2018 proposed rule, CMS wanted to make even more IMPACT Act changes in 2019, including adding items in Section B: Hearing, Speech and Vision; Section C: Cognitive Patterns; Section E: Behavioral Symptoms; Section I: Active Diagnoses; Section K: Swallowing/Nutritional Status; and Section O: Special Treatments, Procedures and Programs (see more details at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/Proposed-OASIS-Items-for-CY-2018-HH-PPS-NPRM.pdf). Expect to see at least some of those changes in future OASIS editions instead, experts say.

"CMS did not finalize many of the proposed assessment items due to concerns regarding burden," Carr tells Eli. "Yet, they finalized eliminating 33 assessment items. This is going to be interesting."

Plan ahead: Home health agencies may have some difficulty mapping out their OASIS-D ramp-up schedules for this year. "Some preparations could begin as soon as [the OASIS-D form] is released, but the problem is that the OASIS-D is not official until it is cleared from [the Office of Management and Budget]," Carr notes. "Vendors will be reluctant to make changes until there is an OMB number."

In the usual rulemaking routine, "there is a 60-day comment period to CMS" and then "OMB publishes a Federal Register notice with a 30-day comment period," Carr observes. "However, the IMPACT Act waived the PRA requirement, so CMS could skip some steps, although, they seem to be following PRA requirements."

CMS already went through the rulemaking comment process for these changes in the 2018 HH PPS proposed and final rules. And the OMB's Federal Register Paperwork Reduction Act notice has a comment deadline of May 11.

Agencies also may have another crack at helping to shape the new form when CMS issues OASIS-D in the proposed and final HH PPS rules for 2019. In the Feb. 28 Home Health Open Door forum, a CMS official noted the agency would issue the new version of OASIS in conjunction with the rules expected in July and November.

With the 2019 proposed rule, "CMS will announce the OASIS-D in the Federal Register and provide another opportunity for comment in accord with their administrative procedures," Carr explains. "That would happen in July."

Then "the dataset could be cleared and finalized by OMB before the final rule, or later," Carr continues. "The schedule for when an official dataset will be available is dependent on OMB."

Bottom line: "We really have no idea when an official version will be issued," Carr says. Stay tuned.

Note: See the Federal Register notice at www.gpo.gov/fdsys/pkg/FR-2018-03-12/pdf/2018-04893.pdf. Supporting materials will be available at www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRAListing.html. See the change table at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/OASIS-2019-Change-Table-for-CY18-HH-PPS-Finalrule.pdf.