Home Health & Hospice Week

Assessment time points added for some.

If the suspension of OASIS data collection for private pay patients saves you time and resources, you're one of the lucky ones. And those savings could change on the heels of a new Medicare memo regarding comprehensive assessments.
 
The Medicare Modernization Act temporarily suspends the requirement to collect OASIS data on non-Medicare, non-Medicaid patients, the Centers for Medicare & Medicaid Services confirms in an April 8 memorandum to surveyors (S&C-04-26). But the law "does not suspend any other aspects of the Comprehen-sive Assessment regulation," CMS insists.

And that includes the timeframes for conducting a comprehensive assessment: at start of care, during the last five days of every 60 days beginning with SOC, within 48 hours of the patient's return to the home from a hospital admission, and at discharge.

These time points "are not OASIS specific and have not been suspended by MMA," CMS stresses in the memo. That means Medicare-certified home health agencies must conduct a complete assessment at each of the time points for all patients, including those with private payors.

Conducting a comprehensive assessment at all those time points "was never a stipulation prior to OASIS," protests Gwen Toney, director of government affairs for the Ohio Council for Home Care. It is clear a comprehensive assessment is required for all patients at SOC, Toney says. But OCHC contends the regulations don't require "a whole new complete 10-page assessment" at the other times required for OASIS, she insists.

"The whole point" of the OASIS suspension "was to reduce the paperwork burden," Toney tells Eli. "With this new interpretation, it's three times worse."

Prior to CMS' December memo announcing the suspension (see Eli's HCW, Vol. XII, No. 45), Ohio surveyors never looked for comprehensive assessments at any time but the start of care, Toney maintains.

The same is true for other states, including Texas. The Texas Association for Home Care wrote CMS about the problem in January. In its response, CMS outlined the points included in the new memo.

And a number of states haven't started imposing this requirement yet, it appears. Surveyors in those states will start citing agencies for lacking comprehensive assessments on private-pay patients at all the time points, thanks to this memo, Toney predicts.

The memo is likely to alert surveyors who were unaware of the comprehensive assessment time points to them, agrees Mary St. Pierre with the National Association for Home Care and Hospice.

The added burden will hit agencies that mainly serve pediatric patients especially hard, Toney forecasts.

"We don't agree with this interpretation," Toney says. "It eliminates the burden relief granted with the private pay suspension."

But OCHC is warning HHAs to change their policies, procedures and practices to reflect the change. "They'll be looking for it" in surveys, Toney warns.

NAHC says its understanding was always that the comprehensive assessment was required at the new time points, according to St. Pierre. Previous to the OASIS regulations, the comprehensive assessment was merely inferred in the duties spelled out for nurses and therapists generating a plan of care, St. Pierre adds.

The burdensome interpretation of this rule reflects CMS' reluctance to give up control over the details of HHAs' operations, experts note. Former CMS official Bob Wardwell urges the agency to "get into the spirit of what Congress was trying to do in MMA, and that was to reduce the paperwork burden."

"A bit more creative thinking on that end would go a long way toward helping agencies recruit and retain nurses in home heath and not diminish quality one iota," contends Wardwell, now with the Visiting Nurse Associations of America.

Editor's Note: The memo is at www.cms.hhs.gov/medicaid/survey-cert/sc0426.pdf.