Medicare Compliance & Reimbursement

Therapy questions could prove tricky.

Come this fall, home health agencies could save a bit of OASIS work when patients return from hospital stays in the last five days of their PPS episodes.
 
The Centers for Medicare & Medicaid Services has agreed to scrap the follow-up OASIS assessment (RFA 4) when a resumption of care assessment (RFA 3) has to be filled out at the same time. CMS announced the change during its April 23 satellite and Internet training session on wound care.

Eliminating the redundant OASIS assessment in this narrow circumstance was a recommendation from the HHS Advisory Committee on Regulatory Reform back in May 2002.

Currently, when a patient has a hospital stay and returns home in the last five days of her prospective payment system episode, the home health agency must at the same time fill out the RFA 3 OASIS to finish out the episode and the RFA 4 OASIS to begin the subsequent episode.

Starting Oct. 1, agencies can just fill out the RFA 3 and use it to generate the case mix category for the next episode as well, explained CMS' Carol Blackford.

CMS has said since the end of 2001 that it's OK to drop the RFA 4 when the patient returns from the hospital in the last five days of the episode, notes consultant Judy Adams with the LarsonAllen Health Care Group in Charlotte, NC. But the difference is that it was acceptable only if the HHA was not claiming a significant change in condition (SCIC) after the resumption of care.

And many agencies couldn't take advantage of the exception, because their HAVEN or other OASIS software systems wouldn't accept it, Adams tells MLR.

"Maybe this time, this process will work," Adams hopes. CMS will release a new HAVEN version Oct. 1 when the change takes effect, CMS noted.

Watch out: There is one hitch with dropping the RFA 4 assessment. The RFA 3 OASIS item on therapy, M0825, will apply to both the current episode and the subsequent episode.

If the answer for M0825 is the same for both episodes, it's no problem. But if the answer is "yes" for the current episode and "no" for the subsequent episode, agencies will have to fix the billing situation by hand, CMS warned.

How to do it: If agencies fill out M0825 as "yes" on the RFA 3 but the patient's following episode won't meet the 10-visit therapy threshold, the PPS grouper will generate the wrong HIPPS code for that episode, explained CMS' Wil Gehne. That means HHAs will have to substitute the non-therapy HIPPS code for the following episode's RAP and final claim, Gehne instructed.

CMS even furnished a handy "translation" chart giving agencies a listing of home health resource groups and HIPPS codes [...]