Home Health & Hospice Week

Take a good hard look at your clinical processes soon to avoid last-minute pressure.

You’ve got about a year before OASIS-C is scheduled to begin, but you’ll be scrambling to comply with the new form unless you begin getting ready now.

In November, the Centers for Medicare &Medicaid Services issued its latest draft of the OASIS retool. The new form for home health agencies makes widespread changes, including the addition of numerous process-based items (see Eli’s HCW, Vol. XVII, No. 42, p. 330). The new start of care form under OASIS-C will have 105 M0 items, compared to the current 76, CMS points out.

The form is likely to undergo some tweaks before CMS issues the final version later this year,but agencies can expect the basic structure to stay the same, experts predict.

You can start some of the most time-consuming parts of OASIS-C preparation now, advised Chicago-based regulatory consultant Rebecca Friedman Zuber in a December audioconference sponsored by Eli, “OASIS-C: What You Need to Know Now About this Major Assessment Overhaul.”

1. Assess clinical processes and make

improvements. The new OASIS-C form asks HHAsto address a wide range of new clinical issues with process-based M0 items -- vaccinations, pain, pressure ulcers, diabetes, cardiac issues, depression, falls, and medications.

CMS has been eager to implement assessment items based on processes, like they have for nursing homes, experts say. Then they’ll be able to use such measures on Home Health Compare and, possibly, to create a five-star rating system such as the one just launched for nursing homes (see Eli’s HCW, Vol. XVIII, No. 1, p. 2).

Maybe you already address all these items, or maybe you’re currently addressing just a few. Either way, now’s the time to review what you’re doing and improve it, Friedman Zuber advised in the session. (See related box, p. 11, for questions to ask yourself in the process.)

Once you have your new and improved clinical processes in place, you’ll have an easier timeanswering the new M0 items.

Example: CMS will add three new items on risk assessment, care planning, and interventions for pain (M1242, M1244, and M1246). You’ll need to look at what standardized tool you use to assess pain and how the care plan addresses management of it.Remember, “pain is the new vital sign,” Friedman Zuber said.

CMS may be using the new tool to impact more than just HHAs, Friedman Zuber added. The new M1326 asks “Are moisture retentive dressings specified on the physician-ordered plan of care?” and M1328 asks “Since the previous OASIS assessment, were moisture retentive dressings used?”

These questions aim to get docs to consider using evidence-based practice for pressure ulcer treatment. “Plenty of data out there shows that moisture-retentive dressings are the way to go for treatment of pressure ulcers,” Friedman Zuber noted.“CMS is clearly using home health as a tool to move physicians in this direction.”

2. Identify screening tools. The new OASIS-C form asks agencies about using four screening tools: for pain (M1242), pressure ulcers (M1300),depression (M1730), and fall risk (M1930). The form also asks about medication review (M2000),Friedman Zuber noted.

If you don’t already have standardized screening tools in place for these items, now is the time to acquire them, Friedman Zuber advised.

3. Train staff and evaluate their competency.

It’s too early to educating training staff on the new OASIS-C form, but you should begin training them now on the new underlying assessment tools you adopt, Friedman Zuber urged.

Train staff, then evaluate their competency with the new tools and add more education if necessary,she said. If you can get that part all down pat before OASIS-C hits, your training on the new form itself will be simpler and the resulting data more reliable.

4. Start talking to software and form vendors.

OASIS-C will have wide-ranging impacts on your operations, Friedman Zuber warned. The new form will affect your billing software, your clinical documentation system and forms, and your HAVEN or other OASIS reporting software.

It’s never too early to begin communicating with your current vendors, or potential new ones, about the changes.

5. Formulate your OASIS-C training

plan. It’s unlikely that CMS will make significant changes to the OASIS-C form, but that’s always a possibility, Friedman Zuber cautioned. Hold off on training on the new form until later in the year--probably in the early fall.

However, you should get staff involved in the steps you’re working on now -- assessing clinical processes and adopting new screening tools, Friedman Zuber counseled. This will help secure staff buy-in and show them how the information they collect will be used.