Home Health & Hospice Week

But you’d better make sure your RFA 5 policies are in order.

If you’re confused about how you’ll handle patient transfers versus discharges to the hospital under 30-day billing, you’re not alone.

One caller in Medicare’s May 15 Home Health Open Door Forum asked if the transition to 30-day billing under the Patient-Driven Groupings Model would necessitate discharging patients to the hospital, rather than just doing a transfer and resumption of care when they come back on service before the end of the 60-day certification period.

“None of the OASIS instructions are changing as a result of PDGM,” one Centers for Medicare & Medicaid Services official clarified in the forum.

“You’ll be doing your transfers and Resumptions of Care the way that you’ve always done them,” another CMS staffer affirmed. “Those requirements don’t change with the PDGM.”

Another unchanging OASIS rule applies to assessments for significant changes in condition. CMS’s recent transmittal clarified that under PDGM’s 30-day billing, diagnosis codes on claims and OASIS assessments won’t necessarily have to match (see Eli’s HCW, Vol. XXVIII, No. 17). That’s because the patient may have a different diagnosis code in the second billing period, but not have a decline or improvement in condition that necessitates an RFA 5 (other followup) OASIS assessment.

In other words: “You don’t need assessments just to make the two documents match,” the CMS official said. “But the other OASIS assessment instructions … are not changing,” he added. So if a SCIC requires a follow-up assessment, you’ll still need to do it — as always.

How do you know when it’s required? That can be tricky. “In the preamble to the compre­hensive assessment regulation, it is noted that a comprehensive assessment with OASIS data collection is required when there is a major decline or improvement in health status,” CMS says in one of its OASIS Q&A documents. “Each agency must determine its own policies regarding examples of major decline or improvement in health status and ensure that the clinical staff is adhering to these policies.”

Watch out: While the SCIC assessment is a longstanding requirement, many home health agencies have gotten lax about performing them, industry experts believe. Make sure your assessment staff know when an RFA 5 is required — and that your policies spell out that information clearly.

See more discussion of how to use RFA 5 at https://qtso.cms.gov/system/files/2018-03/CAT_ 3_04_15_FINAL.pdf.

Another instance in which OASIS rules won’t change are with Medicare’s new data submission timeline. CMS recently shortened the submission deadline for OASIS and HIS data from 36 to 24 months (see Eli’s HCW, Vol. XXVIII, No. 16). “Please note that this change does not affect the OASIS submission deadline” from the Conditions of Participation, a CMS staffer urged.

Remember: “Regulation requires the OASIS be transmitted within 30 days of completion (M0090),” consulting firm Healthcare Provider Solutions in Nashville reminds providers on its website.

Other home health agency issues addressed in the forum include:

• Home Health Compare. You may have to wait a bit longer before you see the refresh for Medicare’s outcomes website. HH Compare is undergoing a software update, and won’t display the refresh until the update is completed successfully, a CMS source told forum attendees.
• RCD. CMS and HHH Medicare Adminis­trative Contractor Palmetto GBA are on track to implement the Review Choice Demonstration in Illinois on June 1, a CMS official said. Illinois agencies’ last day to choose their review option was May 16. After that, Palmetto put them automatically into the 100 percent postpay review choice.