Home Health & Hospice Week

But say hello to a shorter transmission timeframe for OASIS data.

Home health agencies scrambling to meet the seven-day lock date for OASIS data will have one less headache starting this summer.

"We are no longer requiring HHAs to encode OASIS data within seven days of completing an OASIS data set," the Centers for Medicare & Medicaid Services explains in a final rule on OASIS published in the Dec. 23 Federal Register.

"Instead, HHAs will have 30 calendar days from the date the assessment was completed to both encode and transmit completed OASIS data to the State agency or CMS OASIS contractor," CMS notes. The rule will take effect June 21.

CMS isn't changing the usual five-day deadline from start of care that HHAs have to complete the OASIS assessment. But the 30-day transmission deadline is a departure from the current requirement that the agency transmit the assessment no later than the month following the month the assessment was locked.

In some cases, the current requirement gives agencies "more than 60 days from the date the assessment was completed to transmit," notes Linda Krulish, president of Redmond, WA-based OASIS Answers.

Removing the lock requirement allows "HHAs the option of making corrections to OASIS data at any time without edit warnings," CMS notes in the rule that finalizes a 1999 interim final rule on OASIS.

"It's a welcome and overdue move to be re-sponsive to the longstanding problem agencies have had meeting the start of care lock date," cheers Bob Wardwell with the Visiting Nurse Associations of America.

Quicker QI: The change will also make agencies' outcome-based quality improvement (OBQI) and OBQ monitoring (OBQM) reports more timely, CMS adds. "Now that we are requiring HHAs to both encode and transmit completed OASIS data within 30 calendar days, we expect the reports to be available 30 days sooner," the agency says in the rule.

Improving the reports' timeliness by eliminating the reporting lag time is "the biggest benefit to this change," Krulish judges.

Lost opportunity: But CMS has missed the boat by making such minor changes in its OASIS final rule, chastises Wardwell, a former top CMS official. Agencies are "disappointed that CMS lost the opportunity in this rulemaking to make more significant [OASIS] refinements ... that were suggested by the home health community years ago," he tells Eli.

The rate of OASIS change seems "to have slowed from a slow pace to a glacial pace," Wardwell blasts. "With [pay for performance] in the wings, I'm surprised CMS has not given OASIS refinement the priority it needs to happen."

CMS did take the opportunity to codify in the final rule some other OASIS-related changes it already has made, such as assigning unique ID numbers to HHA branches.

Beware Billing Blunders Without Lock Date

While HHAs may welcome the elimination of the stringent lock date, they should make sure it won't slow down their billing, warns consultant M. Aaron Little with BKD in Springfield, MO. "Without the locking requirement ... agencies could experience delays in 'finishing' the assessments, as the assessments need to be finalized prior to billing," Little predicts.

"Even worse ... [Requests for Anticipated Payment] could be billed with a HIPPS code from an OASIS that isn't actually yet finalized and ready for billing," Little warns. Good communication between agency personnel should help prevent that problem.

Agencies should consider implementing their own internal deadlines for finalizing the OASIS assessment once the lock date is gone, Little suggests. The deadline should be "within a number of days," he recommends. "Since clinicians are used to the old seven-day rule, making this the agency policy would be one way to help avoid billing delays." 

Note: The final rule is at www.access.gpo.gov/su_docs/fedreg/a051223c.html scroll down to the Centers for Medicare & Medicaid Services entries.