Home Health & Hospice Week

Tip: Make real-life scenarios part of your staff training.

Come January, your reimbursement, outcomes, star ratings, and more will depend on a seriously revamped OASIS tool.

Use this expert advice to map out your OASIS-D ramp-up now, to make sure you're fully prepared when the new assessment tool hits in the new year:

1. Educate yourself. Although the Centers for Medicare & Medicaid Services announced in previous Home Health Prospective Payment System rules that it would be implementing IMPACT Actrequired revisions to OASIS in 2019, CMS released the OASIS-D draft only recently (see Eli's HCW, Vol. XXVII, No. 12). Make sure to take a look at the changes, particularly the 28 items dropped and the Section GG and Section J items added and expanded (see Eli's HCW, Vol. XXVII, No. 14).

But the changes aren't yet set in stone. A CMS spokesperson tells Eli that "CMS intends to release the draft OASIS-D in July 2018." Afinal version is expected in November.

Stay abreast of what's developing with the tool, urges Diane Magrady, compliance lead with Morton Grove, Illinois-based Pragma-IT, creator of the therapyBOSS therapy documentation software solution. "Agencies should make sure that they are signed up for email updates from CMS and their Medicare Administrative Contractor now so that they are alerted to any changes," Magrady suggests.

2. Work on GG0170C. Experts agree that you should hold off on training staff until the OASIS-D form is more firm and the implementation date is closer. However, you can give your clinicians a leg up on OASIS-D by tightening up how they fill out the current IMPACTAct-required item, GG0170C (Mobility), now, Magrady advises.

Reminder: The current item in the GG "Functional Abilities and Goals - SOC/ROC" section instructs clinicians to "code the patient's usual performance at the SOC/ROC using the 6-point scale. If activity was not attempted at SOC/ROC, code the reason." The activity scored is "Lying to Sitting on Side of Bed: The ability to safely move from lying on the back to sitting on the side of the bed with feet flat on the floor, and with no back support."

GG0170C uses the same scoring scale as the one CMS proposes for the additional GG0170 items in OASIS-D (see box, p. 116).

Home health agencies should "focus on ... the way clinicians are answering the existing GG0170C question," Magrady counsels.

Clinicians may often have trouble distinguishing between the six levels for scoring, says consultant Sherri Parson with Quality in Real Time in Floral Park, New York.

Do this: "Agencies should immediately begin auditing a number of assessments from each clinician who performs OASIS visits," Magrady says. "Identifying staff who misinterpret this question and providing additional education will help when dealing with the remaining questions later."

In addition to just the C "Lying to Sitting" ability, under OASIS-D GG1070 will include items A through M ranging from rolling to walking (see box, p. 116).

Pitfall: Often, the way to score these items will conflict with the similar items in the M1800 section, warns consultant J'non Griffin, owner of Home Health Solutions in Carbon Hill, Alabama. (For specific examples, see Eli's HCW, Vol. XXVII, No. 14.) Make sure your staff know the differences, or risk OASIS errors.

3. Check out comparisons. To get a jump on understanding scoring, Parson recommends that agencies "look at the scoring guidance in the IRFPAI and MDS data sets for these items." The inpatient rehab facility IRF-PAI and the skilled nursing facility MDS assessment tools "provide detailed assessment techniques as well as practice scenarios to practice scoring the new items," Parson notes.

Resource: A link to a the IRF-PAI training manual with GG0170 scoring instructions is at and the SNF MDS Resident Assessment Instrument (RAI) user's manual is online at www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/InpatientRehabFacPPS/IRFPAI.html. Or email editor Rebecca Johnson at rebeccaj@eliresearch.com with "IRF-PAI MDS Manuals" in the subject line for a free PDF copy of both manuals.

4. Map out your training calendar. Setting the training dates for OASIS-D might prove tricky, experts caution. That's because you'll need to balance waiting for the final form and instructions versus time needed to get staff up to speed, throwing in the holiday scheduling craziness at the end of the year.

November and December will be the time to go full throttle on training your staff, since CMS is expected to release the final OASIS-D form in November, advises consultant Anita Werner with Fazzi Associates in Northampton, Massachusetts.

"This is the time for agencies to focus their inservices," Magrady agrees.

Alternatively, you can start training staff as early as September or October if you base general training on the draft form and instructions, Magrady allows. But you'll need to be ready to update the training when the final docs hit.

And anyway, "if you start education too soon, staff will not remember what to do on Jan. 1," Magrady notes.

Advance work: You can start working on updating your relevant materials, such as paper OASIS documents, before educating your staff, Magrady recommends.

5. Use real-life scenarios. Explaining the concepts of the new OASIS-D items and their scoring rules is important, but only does half the job. Use patient scenarios to drive home how to utilize the new tool in the field, Werner urges.

Let your staff test their knowledge of the items by applying them to live practice scenarios, Werner recommends. Using real-life scenarios on paper will also help them test their mastery of the new items - and avoid scoring errors out in the field.

6. Reinforce training. Don't expect your clinicians to grasp the complexities of scoring the GG items after a single one-hour training session, Werner cautions. Your staff will need regular support and reinforcement of the concepts to score the new items accurately.

Try this: Employ tip sheets and other easy to-reference learning tools to remind clinicians of the important guidelines for OASIS-D, Werner recommends.

7. Monitor staff via audits. It isn't enough to teach the new items and scoring techniques to your staff. "They need follow-up," Werner stresses. In January and beyond, audit your assessing clinicians' OASIS-D performance to catch any errors and correct erroneous scoring practices before they become entrenched.

"Monitor responses for the new questions for each clinician to identify any employees who may require additional education," Magrady exhorts.

Tip: Use real-life errors you find in common problem areas as instructional examples in follow-up training for the whole staff - anonymously, of course.

8. Don't forget QA staff. It's not just your frontline assessing clinicians who need training on OASIS-D, Werner emphasizes. Your Quality Assurance staff also need a training program to make sure they are knowledgeable about tricky areas, such as when GG and M1800 item answers should be different versus the same (see Eli's HCW, Vol. XXVII, No. 14).

9. Double-check your vendor. About the time you start OASIS-D staff training in November is "a good time for the agency to check with their software vendor to ensure that the system will be ready for OASIS-D on Jan. 1," Magrady advises.