Home Health & Hospice Week

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Baby, it’s cold outside — but the feds are turning up the heat on your OASIS submission practices, and you’ve got no time to waste in getting into compliance

Reminder: For the first time, the Centers for Medicare & Medicaid Services will require a “minimum submission threshold” for OASIS, the agency said in the 2015 HH PPS rule published in the Nov. 6 Federal Register. Starting July 1, home health agencies will have to hit a minimum OASIS submission threshold of 70 percent under Medi-care’s new “pay-for-reporting performance system model,” the rule says (see Eli’s HCW, Vol. XXIII, No. 39). That means HHAs must successfully submit an OASIS record for 70 percent of episodes qualifying as a “quality episode of care,” according to the rule.

“Only those OASIS assessments that contribute, or could contribute, to creating a quality episode of care are included in the computation” for the benchmark, CMS said in the proposed rule.

HHAs that do not meet the “Quality Assessments Only” benchmark will face a 2 percent reduction in PPS reimbursement rates, CMS says.

CMS rebuffed commenters’ suggestions to put off the OASIS submission compliance date. CMS has settled on July 2015 and believes that’s plenty of time for compliance since the requirement to transmit OASIS has been in place for some 15 years, says OASIS expert and attorney Lisa Selman-Holman of Selman-Holman & Associates and CoDR — Coding Done Right in Denton, Texas.

Don’t put off your submission prep activities until the last minute. “Data regarding current compliance are readily accessible to agencies in their OASIS Error Reports available through CAS-PER,” says OASIS expert Beth Johnson of John-son, Richards & Associates in Brighton, Mich. “Agencies should assign responsibility for scheduled accessing and distribution of these reports, as well as OBQI, OBQM, and PBQI reports, in order to accurately track and respond to opportunities for improvement.”

Don’t miss: CMS also recently proposed changes to the Conditions of Participation for the first time in 25 years, Johnson notes. Included in the proposed changes is a requirement that agencies develop, implement, and maintain an agency-wide, data-driven quality assessment and performance improvement (QAPI) program, she points out.

“The logical first step to compliance is the ability to access data already tabulated for you in order to understand how your agency is performing at baseline,” says Johnson. Begin by taking a look at the CASPER User’s Guide found at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/downloads/HHQICASPER.pdf.