Home Health & Hospice Week

New GG items should top your priority list.

If you think the changes coming to OASIS in January are relatively minor because they involve lots of dropped items and only six new ones, think again.

The Centers for Medicare & Medicare Services announced the list of 28 items it would be removing from OASIS when it released the OASISD draft form last month (see box, p. 107). At the same time, CMS is adding five new items and significantly enlarging the existing GG item (see box, below).

At first glance, it might appear home health agencies would see a net burden reduction thanks to dropping 30 items and adding only six. In fact, in its supporting statement for OASIS-D, CMS estimates a "reduction in clinician burden associated with changes to the HH QRP of 166 hours per HHA annually, or 2,016,386 hours for all HHAs annually."

But that math doesn't tell the whole story, insists consultant Anita Werner with Fazzi Associates in Northampton, Massachusetts. "It's not simple addition and subtraction," she warns.

Why? HHAs welcome the dropping of many of the items, notes OASIS expert Sherri Parson with consulting firm Quality In Real Time in Floral Park, New York. For example, agencies will be particularly happy to say goodbye to items like M1011 (Inpatient Diagnosis), M1017 (Diagnoses Requiring Medical or Treatment Regimen Change Within Past 14 Days), and M1025 (Optional Diagnoses), Parson judges.

But many of the items CMS is eliminating are straightforward ones that are relatively simple and quick to answer, Werner says. That includes items like M1210 (Ability to Hear) and M1220 (Understanding of Verbal Content).

In contrast, the items CMS is adding "are much more time-consuming," Werner tells Eli.

For example: GG0170 currently asks clinicians to assess just lying to sitting on the side of the bed, Parson notes. OASIS-D will expand the GG0170 section greatly, adding 18 subitems, two of which contain their own sub-sub items.

Many of those items, which haven't been required to this extent in the home health setting before, will take a lot more time to complete, Werner expects.

Case in point: GG0170K (Mobility: Walk 150 feet) directs clinicians to assess "once standing, the [patient's] ability to walk at least 150 feet in a corridor or similar space," according to the draft OASIS-D form CMS released last month (see Eli's HCW, Vol. XXVII, No. 12). And GG0170G (Walking 10 feet on uneven surfaces) asks them to assess "the ability to walk 10 feet on uneven or sloping surfaces (indoor or outdoor), such as turf or gravel."

Other GG0170 sub items ask about "rolling left to right, sit to stand, car transfers, walking 50 feet with two turns, and so forth," Parson adds.

Be prepared for clinician difficulty with these items, cautions consultant J'non Griffin, owner of Home Health Solutions in Carbon Hill, Alabama. "Nursing staff are not accustomed to the intensity of rehab questions such as ambulation of the different distances - ranging from 10 feet to 100 feet, on even and uneven surfaces, which may contain turns - during the ambulation as in the GG0170 questions. They already had difficulties answering the one GG question we currently have," Griffin observes.

In addition to being more time-consuming, clinicians may struggle with scoring the GG0170 items accurately. CMS provides a six-point scale ranging from Dependent (01) to Independent (06).

Anticipate difficulties with staff "clearly understanding the difference between some of the scoring options, such as ... between partial/moderate assistance, supervision or touching assistance, substantial/maximal assistance, and so forth," Parson advises.

Interview Questions Also Trickier

Even OASIS-D's new interview questions may bring more burden to HHAs, Werner adds. While they don't require the lengthy skill observation, they are asking for more details than previous OASIS questions.

For example: GG0100D (Prior Functioning: Everyday Activities - Functional Cognition) asks the clinician to "code the patient's need for assistance with planning regular tasks, such as shopping or remembering to take medication prior to the current illness, exacerbation, or injury" on a 9-point scale, Werner points out. That involves a significantly more extensive interview than the current OASIS M1900 with its 3-point scale.

Plus: "The GG questions direct clinicians to plan and document for the patient's condition at discharge, as well as their current performance," notes Diane Magrady, compliance lead with Morton Grove, Illinois-based Pragma-IT, creator of the therapyBOSS therapy documentation software solution. "It will be interesting to see what will happen going forward if discharge goals are not met."

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