Home Health & Hospice Week

Comment early and often.

If you think Medicare needs to change some things about the newly unveiled OASIS-D tool that takes effect Jan. 1, don't wait until the last minute to give program officials a piece of your mind.

The Centers for Medicare & Medicaid Services will have several OASIS-D commenting opportunities for home health agencies and other stakeholders, a CMS spokesperson tells Eli. The first comment period is part of the Paperwork Reduction Act process and closes May 11 (see Eli's HCW, Vol. XXVII, No. 12).

The current draft "OASIS-D is based upon the policies that we finalized in Calendar Years 2017 and 2018 rules," the CMS source notes, referring to the Home Health Prospective Payment System rules.

Then, "based upon the comments received, a revised version will be posted in early summer with an additional review period," the CMS representative explains. "CMS intends to release the draft OASIS-D in July 2018." The agency will post the draft at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/index.html.

CMS will post the revised draft in conjunction with the 2019 HH PPS rule, observers expect, and a final version will be out with the final rule in November.

Take heed: Often, CMS makes few or no substantive changes between the proposed and final rules, industry veterans note. That makes this initial PRA comment period the best opportunity to urge CMS to make any changes necessary to the tool revamped for IMPACT Act compliance.

"Have your voice heard," urges consulting firm Kornetti & Krafft Health Care Solutions.

"Now is the time" to comment, before the new OASIS items are finalized, urges software provider Therapy Boss in a blog post.

OASIS-D aims to "comply with requirements for the Improving Medicare Post-Acute Care Transformation Act of 2014," CMS notes in its supporting statement for the tool. Changes related to IMPACT Act compliance include:

• New standardized items (GG0100, GG0130, GG0170, J1800, J1900) to support measures mandated by the ACT- Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674); and Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631).
• Modification to OASIS items M1311 to support a new pressure ulcer measure to replace the current pressure ulcer measure. The new measure is Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury.

CMS is also adding these new items for standardization to align with the IRF-PAI (Inpatient Rehab Facility) and MDS (Skilled Nursing Facility) assessment tools:

• M1900 Prior Function
• GG0110 Prior Device Use.

Get Ahead Of Common GG0170 Pitfall

"Quite a bit" in the tool "will be different," notes Therapy Boss.

"Changes to the assessment are extensive," agrees consulting firm Fazzi Associates in a post on its website.

And "this is not the last we will be hearing about additions to the OASIS," Therapy Boss adds.

CMS originally proposed in the 2018 HH PPS rule a much larger slate of additions to OASIS, but decided to withdraw many of the items after receiving comments (see Eli's HCW, Vol. XXVII, No. 11). CMS held off on implementing the proposed additions for Section B: Hearing, Speech and Vision; Section C: Cognitive Patterns; Section E: Behavioral Symptoms; Section I: Active Diagnoses; Section K: Swallowing/Nutritional Status; and Section O: Special Treatments, Procedures and Programs.

"Most of the remaining proposed sections are planned to be released in 2020," Therapy Boss says.

"OASIS continues to change as a data set used for the purposes of quality assessment, as well as payment for Medicare certified home health agencies," notes accrediting body Community Health Accreditation Partner (CHAP) on its blog.

Plan now: "As veterans of home health know, changes to OASIS mean changes the software companies must incorporate before January 2019, as well as agency education of staff in the new OASIS items and wording," CHAP says.

Don't let the deadline sneak up on you. "Start your planning for implementation soon," Therapy Boss urges.

In particular: "Reinforce education with clinical staff who may not understand completely how to answer the existing question GG0170C on the current OASIS," the company recommends.

"There will be a number of questions in the new data set with the same formatting, so it is important that they answer both sections appropriately."

Note: See the OASIS-D materials at www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-10545.html.