Home Health & Hospice Week

The "tentative final data set/instrument" and a host of supporting documents -- including a 61-page crosswalk from the current OASIS B to the new OASIS C form and a 74-page response to public comments on the new form--are on the Centers for Medicare & Medicaid Services'Web site.

And home health agencies can expect more new and revised OASIS materials ahead, said CMS's Deborah Terkay, speaking at the National Association for Home Care & Hospice's March on Washington meeting March 23.

CMS plans to revamp Chapter 8 of the OASIS User's Manual, Terkay said in the meeting's home health panel on regulatory issues. In fact, the entire OASIS manual is slated for an overhaul. The new manual will be called the "OASIS Guidance Document," she said in a separate session at the meeting, "Up Close and Personal: The OASIS C Assessment Instrument."

Bonus: The new Chapter 8 will include information on where to look for screening tools indicated under the new form, such as the pain screening item, Terkay revealed.

CMS plans to issue the truly final version of the OASIS C form in late summer, it says on its Web site. Implementation continues to be scheduled for January 2010.

"Don't expect OASIS to ever stay the same," cautioned Angela Richard, with OASIS contractor University of Colorado Health Sciences Center in Denver. Even the latest version 12.2 CMS submitted to the Office of Management and Budget on March 9 could change after the 30-day comment period, Richard told attendees at the NAHC OASIS C session.

The impetus for developing OASIS C was the need to update quality measures, Terkay said.Although "the impact on payment is zero," eventually the OASIS C measures "could be used for refinement to the case mix adjustor," she said.

CMS and its OASIS contractors including Abt Associates of Cambridge, Mass. made many changes to the field-tested OASIS C in response to feedback from testers and comments from more than 140 interested parties, said panel member Deborah Deitz of Abt.

The new OASIS C contains many new process measures, but CMS wants agencies to know that these items are "optional," Richard told listeners. Many of the items will not apply to some patients and agencies can "just say no" even if they do apply, she said. But if CMS develops a quality-based purchasing component (formerly known as pay for performance) to reimbursement, the decision not to incorporate these evidence-based practices could impact payment, Terkay cautioned.

CMS will offer extensive training assistance, including a "Train the Trainer" package and programs for state surveyors and OASIS Coordinators,Terkay said. These are currently under developmentand are scheduled for the fall.

Among the changes outlined by panelist Elizabeth Madigan with OASIS contractor Case Western Reserve University in Cleveland are:

• The transfer OASIS will take longer and contain more items than in the current OASIS B to capture more information for CMS.

• Clinicians will need access to the medical record to do a transfer or discharge OASIS. "OASIS will no longer be a snapshot in time," Madigan said.

• Agencies will need new systems to make process screening easier.

• Everyone will struggle to say "M" items instead of "Moo" items, she joked.