Home Health & Hospice Week

Setting the training schedule won’t be business as usual this time.

You might think you have months before you have to worry about OASIS-E implementation, but think again.

There’s no time to waste with OASIS-E preparation, multiple OASIS experts tell AAPC. That’s even though the updated assessment tool doesn’t take effect until Jan. 1, 2023.

“Time will go quickly and the end of the year will be here faster than we expect,” warns consultant Angela Huff with BKD in Springfield, Missouri. “You won’t want to wait to the end of the year that is peppered with holidays to be starting [OASIS-E] education with your staff,” Huff advises.

“You will be much better to start now and get your staff as comfortable as you can in order to make the transition to this new tool as smooth and the least stressful as possible,” Huff adds.

Wise home health agencies will heed this expert advice:

1. Solidify your OASIS skills. “The majority of OASIS-E items are really OASIS-D carried over, so prep needs to start now to put old issues to bed,” recommends Cindy Krafft with Kornetti & Krafft Health Care Solutions. “This will free up time to focus on the new content later in 2022,” Krafft says.

2. Tackle interview items up front. “Agencies should be getting clinicians familiar with the interview assessment pieces now,” urges Sherri Parson with McBee Associates in Wayne, Pennsylvania. “The Brief Interview for Mental Status (BIMS), the Confusion Assessment Method tool (from CAM) and the Patient Mood Interview (PHQ-2-9) could be implemented now and would add more screening to notify the physician/ provider of problems,” Parson suggests.

“By implementing them now, clinicians would be more confident and proficient with these assessment tools once OASIS-E begins,” Parson notes.

3. Set training clock to ‘early.’ Your usual M.O. may be to schedule training a few months out when an OASIS change is taking place. But this year should be different, with the Home Health Value-Based Purchasing implementation date also set for Jan. 1. “With HHVBP coming on line at the same time as OASIS-E, agencies should start sooner rather than later to provide education for their staff,” Huff advises. “Take advantage of the newly released draft and share it with your staff now so that they can start becoming familiar with the tool,” she suggests.

The OASIS-E-HHVBP overlap “will mean that agencies will have to ensure that they hit the ground running with the new tool,” Huff emphasizes.

4. Prioritize SDoH. The new Social Determinants of Health — Ethnicity. Race, Language, Health Literacy, Transportation, and Social Isolation — are more than points to check off. “These items are complex in nature, but will take our care planning to new levels as we bridge the gap of disparities of health delivery in our communities,” Parson tells AAPC. “CMS has asked for suggestions on how to further hold agencies accountable for performance in this area, so now would be a good time — ahead of OASIS-E — for agencies to develop processes for implementing SDoH in the care planning of their patient populations,” she encourages.

5. Link OASIS and VBP training. While the simultaneous deadline for OASIS-E and HHVBP implemen­tation is inconvenient, “it is an opportunity ... to pair up education on both of these topics,” Huff points out. Doing so allows “the clinicians [to] understand the relevance of which items on the new OASIS-E also impact on HHVBP and PDGM as well,” she says.

6. Tap free education resources. The Centers for Medicare & Medicaid Services has promised to provide OASIS-E training throughout this year. “Look for education opportunities from CMS and other resources to take advantage of for your organization,” Huff recommends. HHAs should “spread them out on a consistent manner throughout the year to allow time for comprehension and understanding,” she suggests.

7. Comment on OASIS-E. While the OASIS-E draft is probably in nearly its final form, HHAs do have an opportunity to comment on the tool. Those comments could influence future versions of the document, too.

“Interested persons are invited to send comments regarding our burden estimates or any other aspect of this collection of information, including the necessity and utility of the proposed information collection for the proper performance of the agency’s functions, the accuracy of the estimated burden, ways to enhance the quality, utility, and clarity of the information to be collected, and the use of automated collection techniques or other forms of information technology to minimize the information collection burden,” CMS notes in a Feb. 9 Federal Register notice.

Comments are due April 11. Agencies can comment using a link at http://www.regulations.gov/docket/CMS-2022-0032/document or a link or regular mail address at http://www.federal-register.gov/documents/2022/02/09/2022-02738/agency-information-collection-activities-proposed-collection-comment-request.