Medicare Compliance & Reimbursement

R0320. Food B. Within the past 12 months, the food you bought just didn’t last and you didn’t have money to get more. (Responses 0. Often true; 1. Sometimes true; 2. Never true; 7. Patient declines to respond; 8. Patient unable to respond)

R0330. Utilities. In the past 12 months, has the electric, gas, oil, or water company threatened to shut off services in your home? (Responses 0. Yes; 1. No; 2. Already shut off; 7. Patient declines to respond; 8. Patient unable to respond)

“We are proposing to require HHAs collect and submit four new items in the OASIS as standardized patient assessment data elements under the SDOH category because these items would collect information not already captured by the current SDOH items,” CMS explains in the rule. “Specifically, we believe the ongoing identification of SDOH would have three significant benefits. First, promoting screening for SDOH could serve as evidence-based building blocks for supporting healthcare providers in actualizing their commitment to address disparities that disproportionately impact underserved communities. Second, screening for SDOH advances health equity through identifying potential social needs so the HHA may address those with the patient, their caregivers, and community partners during the home health episode and discharge planning process, if indicated. Third, these SDOH items would support ongoing HH QRP initiatives by providing data with which to stratify HHAs’ performance on current and future quality measures to improve care quality across different populations,” the rule says.

Transportation Item to Get a Makeover

CMS also wants to modify the current OASIS item on transportation.

Old way: The current item, A1250: Transportation asks “Has lack of transportation kept you from medical appointments, meetings, work, or from getting things needed for daily living?” It includes five responses with the instruction to check all that apply: A. Yes, it has kept me from medical appointments or from getting my medications; B. Yes, it has kept me from non-medical meetings, appointments, work, or from getting things that I need; C. No; X. Patient unable to respond; Y. Patient declines to respond.

New way: New item R0340. Transportation would read “In the past 12 months, has lack of reliable transportation kept you from medical appointments, meetings, work, or from getting things needed for daily living?” with four responses: 0. Yes; 1. No; 7. Patient declines to respond; 8. Patient unable to respond.

The proposed change will align the item “with the Transportation category collected in our other programs,” CMS explains in the rule. In addition to simplifying response options, the new item would “revise the look-back period,” CMS adds. Instead of a six- to 12-month lookback period, the new item will have a 12-month period only to “reduce ambiguity for both patients and clinicians, and therefore improve the validity of the data collected.”

Price tag: Implementing the new and revised items in 2027 will cost about $12.6 million, CMS estimates.

Other OASIS changes proposed in the rule include:

• All-payer start date: CMS wants to “change all-payer data collection to begin with the start of care OASIS data collection timepoint instead of discharge timepoint,” the agency says in the rule.

Reminder: HHAs have the option of submitting OASIS data for all payers starting on January 1 through June 30, 2025, “but we will not use that phase-in data to make a compliance determination,” CMS reviews in the rule. “The new all-payer OASIS data reporting will be required beginning with the CY 2027 program year, with data ... required for patients discharged between July 1, 2025, and June 30, 2026,” the agency specifies.

Last year’s home health rule said the collection time point would be discharge, but CMS has changed its mind. “Using the SOC time point ensures agency demographics (for example, Agency’s CMS Certification Number (CCN), State and Branch ID#s) and patient demographics (for example, patient name, State, zip code, Social Security number (SSN), gender, date of birth (DOB), payment source) are collected for each non-Medicare/non-Medicaid patient assessment at the start of all-payer OASIS data collection,” CMS notes. “After these are collected and submitted with the SOC assessment, they are resubmitted with each subsequent OASIS submission (that is, ROC, recert, other follow up, transfer, discharge, death at home). Using the SOC time point would ensure that baseline data is available for use in calculating or risk-adjusting quality measures, and in linking to prior OASIS assessments.”

Plus: CMS could use the data for matching “to support use of the current quality assessments only (QAO) metric used in the annual payment update (APU) calculation,” CMS adds.

New HHQRP measure concepts. “We are seeking input on the importance, relevance, appropriateness, and applicability of each of the following concepts under consideration for future years in the HH QRP: vaccinations, depression, pain management, and substance use disorders,” CMS says in the proposed rule.

This narrowed-down step comes after an RFI on the topic in last year’s rule and a December 2023 Technical Expert Panel meeting on the matter, the proposed rule says. The vaccination measure would be a composite, “which could represent overall immunization status of patients such as the Adult Immunization Status measure in the Universal Foundation,” the rule says.

A depression measure may use a tool “similar to the Clinical Screening for Depression and Follow-up measure in the Universal Foundation” and the substance use measure could look like the Initiation and Engagement of Substance Use Disorder Treatment measure included in the Universal Foundation of Quality Measures,” CMS adds.

The new and revised OASIS items are at www.cms.gov/files/document/proposed-hhqrp-sdoh-item-mockup-june-2024.pdf.