Home Health & Hospice Week
OASIS Burden Looms Large
OASIS-E additions are no walk in the park. Medicare officials do acknowledge that the proposed expansion for home health agencies to collect OASIS data on all patients regardless of payer comes with costs. But the program’s estimates are sorely lacking, multiple providers say in their comment letters. “The added administrative burden associated with the expansion of OASIS and the implementation of OASIS-E beginning on January 1, 2023 is considerable,” says Joan Doyle, CEO of Penn Medicine at Home in its comment letter on the 2023 proposed rule. “This proposition is adding further working time required by home health clinicians but decreasing reimbursement, thus making field staff do more for less,” protests Julie Rhoades from Pennsylvania in her comment letter. “The conversion to OASIS-E at the beginning of January 2023 will require additional training time as well as take staff longer to complete as there are so many changes and expanded areas of assessment within this version,” Kay Findlay from Kansas says in her comment letter. “So, at a time when agencies are already stressed to the maximum, and facing many additional regulatory requirements, we are also being told that we will be doing all this for even less than we are currently receiving in reimbursement,” she says. And “in comparison to other practice settings, the requirements of many of the designated assessment items as part of the OASIS far outweigh other practice settings that, in turn, represent much larger patient populations and reimbursement spend,” points out Matt Janes in his comment letter. OASIS-E “contains several new complex assessment items,” National Association for Home Care & Hospice officials point out in the trade group’s comment letter. “The HHA workforce is already overburdened by administrative requirements, and as CMS adds more SPADEs to the OASIS, there is less time for patient care,” laments Amanda Newell with the Tennessee Hospital Association. Providers are happy to provide CMS with some specifics. “We estimate that the additional work involved with OASIS-E will require approximately 30 minutes of additional documentation time for every patient,” Doyle shares. “Introducing OASIS reporting requirements for patients previously not part of the OASIS reporting program also will add to home health providers’ administrative burden as providers complete paperwork that previously was not required of them,” she points out. The addition of a cognitive assessment to OASIS-E “is further adding in-home time and documentation time to a process that already takes 2 to 5 hours to complete,” says Rhoades, a home health physical therapist. “Based on our company’s records, the time required to complete an OASIS-E Start-of-Care (SOC) assessment is 184.32 minutes or just over 3 hours,” shares Neil Pruitt Jr. with PruittHealth in his comment letter. “This stands in stark contrast to CMS’ estimate of 57.3 minutes,” Pruitt adds. “CMS has significantly underestimated the burden of this proposal and should reexamine its analysis,” he urges.
Home Health & Hospice Week
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OASIS Burden Looms Large
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