Home Health & Hospice Week

Plus: OASIS-E training is coming to you this summer.

You may be feeling you’re just getting a handle on no-pay RAPs, but their successor is just around the corner.

Recap: No-pay Requests for Anticipated Payment just took effect in January 2021. But in January 2022, Notices of Admission will replace no-pay RAPs — and you’d better be prepared for them.

The good news about NOAs is that you’ll only need to submit one notice to cover a 60-day episode, reimbursement experts point out. Currently you must submit a no-pay RAP for every 30-day billing period.

The bad news is that if you miss or mess up the NOA, you’re out payment for two billing periods instead of just one, they warn.

The Centers for Medicare & Medicaid Services now has issued an NOA Companion Guide with details for the transactions for systems developments, a CMS staffer said in the agency’s April 13 Home Health Open Door Forum. The 11-page guide is at www.cms.gov/files/document/home-health-notice-admission-837i-companion-guide.pdf.

Watch for two Medicare transmittals with NOA details coming next month, he added.

Other home health topics addressed in the forum include:

• OASIS-E. Last year, CMS bumped OASIS-E from its Jan. 1, 2021 start date to give agencies a break during the COVID-19 public health emergency. “HHAs will be required to use OASIS-E … beginning with discharges and transfers on January 1st of the year that is at least 1 full calendar year after the end of the COVID-19 PHE,” CMS said in an interim final rule published in the May 8, 2020 Federal Register (see HCW by AAPC, Vol. XXIX, No. 17). “For example, if the COVID-19 PHE ends on April 30, 2021, home health agencies will be required to begin collecting data using the updated versions of the item sets beginning with patients discharged on January 1, 2023,” CMS said on its OASIS Data Sets webpage.

The COVID-19 PHE is still going with no end in sight (see story, p. 118). But an announcement in the forum left agencies wondering if CMS may implement OASIS-E in January 2022 anyway. CMS will furnish training and materials on the updated assessment tool this summer, a CMS source told forum attendees.

“Sometime this summer, CMS plans to provide interim guidance for HHAs regarding the delay of the Outcome and Assessment Information Set (OASIS) E,” the National Association for Home Care & Hospice reports in its member newsletter. CMS did not respond to an AAPC question about the OASIS-E implementation date by press time.

NAHC thinks the original timeline is still intact, however. “My guess is that they have the materials ready, why not release them,” NAHC’s Mary Carr tells AAPC.

When it does arrive, OASIS-E will contain standardized patient assessment data elements (SPADEs) and data collection for transfer of health (TOH) quality measures, CMS noted in last year’s IFR. An OASIS-E draft is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/OASIS-Data-Sets.

• Quality measure removal. As scheduled, this July CMS will remove five home health quality measures from Home Health Compare, a CMS staffer reminded attendees: Depression Assessment Conducted; Multifactor Fall Risk Assessment Conducted for All Patients Who Can Ambulate; Diabetic Foot Care and Patient/Caregiver Education Implemented during All Episodes of Care; Pneumococcal Polysaccharide Vaccine Ever Received; and Improvement in Surgical Wounds.

The removal aims “to address the Meaningful Measures Initiative,” CMS said in 2019 home health final rule at https://www.govinfo.gov/content/pkg/FR-2018-11-13/pdf/2018-24145.pdf (More details about the QMs’ removal are in HCW by AAPC, Vol. XXVII, No. 26).