Home Health & Hospice Week

Silver bullet: Check Final Validation Reports.

There are many scenarios in which an OASIS file may slip through the cracks and cost you all the reimbursement for that episode under the new OASIS matching edit. But there are surefire strategies you can use to make certain that doesn’t happen.

Consider this advice from the experts to keep the new edit from crippling your cash flow:

1. Install a software auto-check. Your first line of defense against OASIS-related claims denials “would be to work with the EMR software vendors to build an edit when billing the [End of Episode claim] that looks in the system to confirm whether or not the OASIS has been submitted,” advises billing expert M. Aaron Little with BKD in Springfield, Mo. Your internal edit should then, “in turn, prevent the claim — or at the very least, give a warning — when the OASIS has not been transmitted.”

2. Or implement a manual check. If your system isn’t up to an automated check within the EMR, “the individual(s) in the agency responsible for transmitting the OASIS should be communicating and coordinating with the billing department to have a structure in place to confirm the OASIS has been submitted prior to EOEs being billed,” Little recommends.

3. Check the Final Validation Report. While an automated check can be handy to stop claims denials before they start when you haven’t submitted OASIS, another pre-billing check is essential to make sure the OASIS file has actually been accepted into the ASAP system, stresses Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tenn. The only way to do that is to access the Final Validation Report in the system.

Resource: See the details about accessing and reading the reports in Appendix A of the CASPER Reporting HHA Provider’s User Guide at www.qtso.com/download/Guides/hha/cspr_appA_hha_prvdr.pdf. Reports are available within 24 hours of OASIS file submission, the Centers for Medicare & Medicaid Services says in the OASIS Submission User’s Guide.

Checking the Final Validation Report for each claim will head off billing when OASIS files are missing in common scenarios such as software failures, personnel turnover and vendor problems (see story, p. 66).

4. Know when ‘complete’ isn’t complete. Don’t confuse a message you receive while submitting a file with acceptance of validation, warns Richter Healthcare Consultants in a blog post.

“The ‘Upload has been completed’ is only an indication that the file has been received and does not mean the file validated successfully,” the consulting firm explains.

Tip: You can review your file status by selecting the “Submission Status” link in the ASAP application, the Twinsburg, Ohio firm says. The file will be classified as Waiting, Processing, Error or Completed.

5. Check the whole thing. If you submit a batch of 100 claims, you need to check to see they were all accepted, Gaboury advises.

6. Be alert for errors. “The best agency on any given day is only as good as its people and processes on that very day,” Little observes. If your Final Validation Report check requires a staffer to manually scan the reports and then enter a date into the system to say it was checked, you are relying on that person’s report scan to be thorough and accurate.

When denying a claim under this edit, the HHH Medicare Administrative Contractor will use Group Code: CO, CARC: 272, RARC: N/A, and MSN: 41.17, CMS says in CR 9585.

7. Plan for disruptions. If you know you are going through a potentially disruptive event like biller turnover or a software conversion, train relevant staff on how to spot potential problems with OASIS submissions and prevent denied claims under this edit.

8. Don’t worry about these exceptions. This edit doesn’t apply to RAPs, Discharge OASIS Assessments, EOE claims submitted before the 30- day OASIS deadline, or OASIS assessments submitted late as long as they are present at the time of the final claim (see more details about these exceptions in Eli’s HCW, Vol. XXVI, No. 7).

Tip: The edit will “be comparing the M0090 date to the claim receipt date” to determine whether the OASIS is past the 30-day deadline, a CMS official clarified in the Feb. 8 Home Health Open Door Forum.

9. Monitor for Medicare system errors. Appeals may be nigh impossible if there are software or other problems on your end, but Medicare claims or OASIS system errors are a different story, points out Rose Kimball of Med-Care Administrative Services in Dallas. Keep tabs on whether “the edit does not get installed and implemented correctly” or the systems have other problems that result in denials, Kimball recommends.