Medicare Compliance & Reimbursement

For example: The new OASIS C form, which the Centers for Medicare & Medicaid Services expects to replace the current OASIS B-1 form in 2010, eliminates the "prior status" column for activities of daily living.

Many of the 142 commenters on the proposed OASIS C form applauded this change, CMS notes in its 74-page summary of the comments that were due in January.

Another positive change for ADLs is adding the word "safely" to the items.

For example: On the OASIS C form, M1830 will say "Bathing: Current ability to wash entire body safely." The item for bathing on the OASIS B-1 form, M0670, currently just says "Bathing: Ability to wash entire body."

Commenters liked other changes about the ADLs too. Splitting the current response 1 for M0700 on ambulation into two options on the new OASIS C form is a popular revision. Currently, response 1 for the item says, "Requires use of a device (e.g., cane, walker) to walk alone or requires human supervision or assistance to negotiate stairs or steps or uneven surfaces."

OASIS C will list two options. Response 1 will say, "With the use of a one-handed device (e.g. cane, single crutch, hemi-walker), able to independently walk on even and uneven surfaces and negotiate stairs with or without railings." And response 2 will say "Requires use of a two-handed device (e.g., walker or crutches) to walk alone on a level surface and/or requires human supervision or assistance to negotiate stairs or steps or uneven surfaces."

Commenters liked being able to show the progression from a walker to a cane, they said.

The revisions could have used even more specifics, though, the National Association for Home Care & Hospice suggested in its comment letter on the proposed OASIS C form. NAHC wanted to see differentiation between ascending and descending stairs, curbs, and multiple steps in the item, it said.

Incontinence: Commenters also praised the addition of several response options to the M0 item on urinary incontinence. OASIS B-1 currently offers three responses for M0530: timed voiding, during the night only, or day and night. OASIS C will add "occasional stress incontinence" and "during the day only" to the M1615 response list.

Toileting: HHAs also liked changes to the toileting M0 item. Currently M0680 says, "Toileting: Ability to get to and from the toilet or bedside commode" and has five responses each under the prior and current categories.

In the OASIS C form, the item will be split into two. M1840 will say "Toilet Transferring: Current ability to get to and from the toilet or bedside commode safely and transfer on and off toilet/commode" with five responses. M1845 will say "Toileting Hygiene: Current ability to maintain perineal hygiene safely, adjust clothes and/or incontinence pads before and after using toilet, commode,bedpan, urinal. If managing ostomy, include cleaning area around stoma, but not managing equipment" with four responses.

The OASIS C form splits another item into two: M0400 on hearing and comprehension. Currently, OASIS B-1 covers "Hearing and Ability to Understand Spoken Language in patient's own language (with hearing aids if the patient usually uses them)."

In OASIS C, the item will become M1210 with the description: "Ability to hear (with hearing aid or hearing appliance if normally used)" with four responses. M1220 will carry the description: "Understanding of Verbal Content in patient's own language (with hearing aid or device if used)" with four responses.

Note: The new OASIS C form and CMS's response to public comments is in the "Downloads" section at www.cms.hhs.gov/HomeHealthQualityInits/06_OASISC.asp.