Home Health & Hospice Week

Use new materials from CMS to further your staff ’s OASIS education.

Hopefully your OASIS-D prep in 2018 is paying off with a smooth transition to the newly revamped assessment tool in the new year. But don’t let up on the gas when it comes to OASIS training.

Why? As always, your payment and outcomes data depend on your accurate OASIS coding. “Payment items are not changing in OASIS-D,” notes consulting firm Kornetti & Krafft Health Care Solutions. But both existing payment items and new items that don’t directly impact pay must be consistent, or you risk raising eyebrows on both payment and program integrity fronts.

And remember, it’s not just your own OASIS and documentation that need to match up now that the Centers for Medicare & Medicaid Services has implemented items in Sections GG and J that span multiple types of post-acute care settings. In the newly finalized OASIS-D Guidance Manual, CMS calls the additions the “standardized patient assessment data elements (SPADEs), added to meet the requirements of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act).”

“The addition of GG0130 and GG0170 on the Skilled Nursing Facility Minimum Data Set (MDS), the Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI), the Long Term Care Hospital Continuity Assessment Record Evaluations Tool (LTCH CARE), and [OASIS] will ensure that CMS can track assessed patient function across the continuum of PAC settings,” emphasizes Diane Magrady, compliance lead with Morton Grove, Illinois-based Pragma-IT, creator of the therapy BOSS therapy documentation software solution. “This will help to … identify entities who try to ‘game the system’ by manipulating assessment data in an attempt to show greater improvement overall,” Magrady says on the company’s blog.

Warning: “Since other facilities are using the same questions with the same scale to assess your patient’s function, CMS will probably review assessments across the post-acute care spectrum,” Magrady cautions. “If your start of care assessment paints a completely different picture than the facility’s discharge assessment, you’re going to get an ADR to review your chart.” In that case, you must “make sure your documentation is defensible,” she urges.

On the bright side, the standardized items will also help to “identify entities whose treatment plans provide greater improvement or decline in similar patient demographic populations,” Magrady adds. Of course, if your outcomes lag behind those of other settings, that could turn into a negative.

Tip: “If your patient had a recent facility stay, consider reaching out to the facility for information about the patient’s typical level of function,” Magrady suggests.

CMS seems to agree that could be a good strategy in a new question-and-answer set released in mid-December.

Question: “Would it be okay to take information from another facility to complete an initial assessment?” an agency asked.

Answer: “The response-specific instructions state that coding should be based on a functional assessment that occurs at or soon after the patient’s SOC/ROC. Scores are to be reflective of the patient’s baseline and should be based on observation of activities to the extent possible. Direct observation is preferred, but performance may be based on reports from the patient, clinicians, care staff, and/or family,” CMS responds. “While documentation from a prior care setting may be helpful in the assessment process, it is not expected that functional status scores from a prior care setting would automatically be utilized as the functional status code for today’s assessment.”

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CMS announced on Dec. 15 that the Office of Management and Budget had given final approval to the OASIS-D form and Guidance Manual, but didn’t post them until Dec. 20. See the manual in the “Downloads” section online at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIOASISUserManual.html.

On Dec. 17, CMS posted “post-training materials” from its big Nov. 6 and 7 in-person OASIS-D training session, including a 106-question Q&A set, at in the “Downloads” section at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Home-Health-Quality-Reporting-Training.html. CMS also revised some slides from the presentation to eliminate confusion.