Home Health & Hospice Week

OASIS:

You Can Opt Out Of These OASIS Items Under PDGM

That only goes for Medicare, new question-and-answer set clarifies.

The Patient-Driven Groupings Model will give you a whole bunch more work, but you can take some newly clarified opportunities to slightly lighten your OASIS load — if you can keep the rules straight.

The Centers for Medicare & Medicaid Services’ new OASIS question-and-answer set backs up earlier instructions indicating that home health agencies can use a “=” if they decline to complete newly optional items on OASIS under PDGM.

For example: M2200 (Therapy Need) will no longer determine payment under PDGM. That item is included on the list of 23 items that will become optional at certain timepoints under the payment system. CMS includes the list in its OASIS-D1 Update Memorandum at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/OASIS-D1-Update-Memorandum_Revised_May-2019.pdf and its OASIS Data Submission Specification Version 2.31.0 issued in May at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/v2-31-0-OASIS-D1-changes-DRAFT.pdf.

HHAs can enter the “=”if they choose, or software vendors can even hard code the optional items with an equal sign, CMS clarifies in the Q&As.

Plus: Even though M2200 is optional only at the Followup timepoint, “agencies may code M2200 Therapy Need with NA — Not Applicable for assessments where the data is not required for the patient’s payer (including all Medicare FFS assessments),” CMS explains.

However: “Since M2200 is used for risk adjustment for OASIS-based functional outcomes, agencies may elect to enter the estimated number of therapy visits planned for the 60-day certification period, even for assessments where the data is not required to establish case-mix for payment,” CMS points out.

Plus: Keep in mind that other payors may require those fields for their own “PPS-like payment models,” CMS says. “In such cases, agencies should follow instructions from individual payors directing data collection by patient.”.

Note: See the 37 Q&As, many of which ad- dress PDGM, at https://qtso.cms.gov/system/files/qtso/CMS_QA_October_2019_08_26_19_FINAL.pdf.

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