Home Health & Hospice Week

Don't forget to submit your comments on the PPS proposal by June 26.

At first glance, the functional domain under the prospective payment system refinements appears unchanged. But look closer, and you'll see big differences that could significantly impact your payment.

What's the same: The six OASIS case mix items that make up PPS' functional domain remain the same--M0650/M0660 (Dressing), M0670 (Bathing), M0680 (Toileting), M0690 (Transferring) and M0700 (Ambulation).

The functional domain case mix items "stand alone as they're scored individually," explained consultant Mark Sharp in last month's Eli-sponsored audio-conference on the proposed PPS refinements. Scoring each item by itself is "consistent with current environment," noted Sharp, with BKD in Springfield, MO.

That's a stark contrast to the clinical domain changes, which dropped and added some case mix questions and greatly increased the interaction between M0 questions for scoring (see Eli's HCW, Vol. XVI, No. 21).

What's different: But the functional domain has its share of changes too, experts point out. Point values for most case mix items have dropped, says Abilene, TX-based consultant Bobby Dusek. And the points are different based on which episode the patient is in and number of therapy visits.

Clinicians filling out OASIS are going to have a difficult time keeping in mind the point values of each case mix item according to which episode it is, expects consultant Melinda Gaboury with Healthcare Provider Solutions in Nashville, TN.

For example: Nurses and therapists can now look at M0650/M0660 and know that a patient receives 4 points if they check box 1, 2 or 3 in the OASIS assessment. Under the PPS proposed changes, the patient will receive anywhere from 2 to 6 points for the same answer, depending on the episode and therapy level.

And clinicians must realize the answers to the functional M0 questions affect more than the functional domain score. The clinical domain case mix questions on diagnosis (M0230/M0240/M0246) award points for some neuro diagnoses only when certain functional domain item scores are also present.

For example: A primary or other diagnosis of Neuro 4 (Multiple Sclerosis) garners zero case mix points alone, but a whopping nine points if paired with an answer of 2 or more in M0670 or M0680 in the third or later episode. In contrast, an MS diagnosis gets a straight-up 20 points under current PPS.

Bottom line: OASIS accuracy will be more important than ever, since even straightforward case mix items have multiple reimbursement effects.

Don't Miss Your Chance To Comment

The May 4 Federal Register notice erroneously listed July 3 as the comment due date. But the deadline for commenting on the proposed PPS refinements is indeed June 26 as the Centers for Medicare & Medicaid Services indicated in its April 27 issuance of the proposed rule, Sharp pointed out.

Be sure to get in your comments by that date, industry representatives stress. Including information on the proposed rule's specific impact on your organization could be influential.

"Share your concerns about things that are negative, share your encouragement to continue on with things that are positive," Sharp urged. "Be involved and make your comments known."

Note: The proposed PPS rule is at www.cms.hhs.gov/HomeHealthPPS/downloads/CMS-1541-P.pdf. The case mix point values are in Table 2a.