Home Health & Hospice Week

Seize your last chance for training before V codes take effect.

If you're not up to speed with the new OASIS version by Oct. 1, the system will start spitting out your OASIS assessments like a soda machine spits out a crumpled dollar.

So the Centers for Medicare & Medicaid Services reminds home health agencies in a question-and-answer document based on its Aug. 20 teleconference with OASIS software vendors.

"For any record with a completion date (M0090) of October 1, 2003 or later, the use of version 1.40 data submission specifications is required," CMS says in the Q&A. OASIS assessments that don't conform to 1.40 specs "will receive a fatal record error causing the record to be rejected and the data will not be stored in the state database," CMS warns.

HHAs will receive no grace period on this requirement, CMS insists - Oct. 1 is zero hour. And OASIS rejections will wreak billing and survey havoc, experts warn.

The most dramatic change in OASIS version 1.40 is the change to diagnosis coding items. HIPAA compels CMS to require in October that HHAs begin using V codes as primary and secondary diagnoses (M0230/M0240) and E codes as secondary diagnoses.

To preserve an agency's payment for a higher-paying primary diagnosis that's bumped by a V code in M0230, agencies can put the higher-paying diagnosis in a newly created OASIS item - M0245 (see pdf of Eli's HCW, Vol. XII, No. 13, p. 101).

If staff aren't trained to use M0245, agencies could lose hundreds of dollars per patient by failing to register the higher-paying diagnosis code. And if HHAs fail to use V codes in M0230 when appropriate, they'll be violating CMS reimbursement regulations as well as HIPAA requirements.

Many agencies wanted to wait to furnish training until close to the onset of V codes, says consultant Pam Warmack with Clinic Connections in Ruston, LA. Employees learn best when the item on which they're trained occurs fairly soon, and HHAs don't want to waste time training staff who leave before the change occurs, Warmack notes.

The length of time needed for training will depend on a number of factors, says consultant Linda Rutman with the Charlotte, NC-based LarsonAllen Health Care Group. The larger the number of admission nurses and the smaller the amount of quality improvement review of OASIS assessments before submission, the longer the training period must be, Rutman predicts.

Ideally, most HHAs should have begun training their staff on V codes July 1, Warmack tells Eli. But in the real world, it's often only management that has an inkling that V codes are coming in only a little more than a month, she acknowledges.

If you haven't yet done so, now's the time to get cracking with an application-based training program for those staff responsible for coding and reimbursement in your agency, Warmack advises. "The best way to learn the principles behind the addition of the V and E codes is to use existing clinical records and practice coding the diagnoses under the new allowances," she counsels.

Agencies unsure of how the diagnosis coding changes will affect billing and care plans can refer to CMS' new Q&A.

"There is no place for entering the diagnosis in M0245 on the UB-92" claim form, CMS explains in the document.

But the diagnosis had better show up on the plan of care somewhere, CMS says. "M0245 is considered a 'pertinent diagnosis' and is expected to be available on the agency Plan of Treatment," the Q&A stresses.

Editor's Note: The Q&A is at www.cms.hhs.gov/oasis/82003svt.pdf.