Medicare Compliance & Reimbursement

If you've already begun your OASIS C prep based on the form CMS released back in March, you should be in good shape. That's because the newest OASIS C form the Centers for Medicare & Medicaid Services issued July 15 contains only minor changes, notes OASIS expert Patricia Jump with Acorn's End Training & Consulting in Stewartville, Minn.

"No new questions have been added and no questions have been deleted," Jump tells Eli. "The number of items remains the same and the OASIS numbering remains the same."

Hold on: The newest OASIS C form still could undergo changes before final implementation in January, however, CMS points out. The agency issued this draft form,which still lacks Office of Management and Budget approval, for its vendor training conferences this month.CMS also issued new OASIS C data specs, version 2.0.

"These specifications should be considered provisional or draft and are subject to change until the final specifications are published," CMS stresses on its Web site.

However, experts agree that agencies can consider the new OASIS C form all but final for planning purposes. Changes from the version released in March and this newest version, 12.4, largely center on wound questions, particularly those for pressure ulcers, Jump notes.

For example: The March version of the OASIS C form asked in M1308 for the number of unhealed pressure ulcers and whether they were (1) present and (2) present on the most recent start or resumption of care. Version 12.4 rewords those timeframes to make clear that Column 1 indicates ulcers currently present and Column 2 indicates ulcers listed in Column 1 that were present at SOC or ROC, Jump points out.

Another example: In the instructions for M1310, M1312, and M1314, which ask for the length, width, and depth of the largest unhealed pressure ulcer, the form now instructs agencies to record only Stage III or Stage IV pressure ulcers. "If no Stage III or Stage IV pressure ulcers, go to M1320," version 12.4 now reads. Another change is that a number of M0 items that have check-box grids now have numbers assigned to the grid options, Jump notes. For example, in M1900 on prior functioning activities of daily living, the grid options of "independent," "needed some help," and "dependent" are now assigned values of 0, 1, and 2, respectively.

One element that has stayed the same is the one-day timeframe in M2002 (Medication followup) and M2004 (Medication intervention). Those items ask whether the home health agency contacted the physician within one calendar day to resolve "clinically significant medication issues, including reconciliation." The one-day standard may be hard to meet, expects Chicago-based regulatory consultant Rebecca Friedman Zuber.

CMS also rejected a suggestion from the American Physical Therapy Association to add one more option to M1860 (Ambulation/Locomotion).

APTA wanted to see an option added for using a onehanded device to walk with human supervision or assistance, according to the trade group's comment letter on the March form.

Instead, CMS kept the options that go from using a one-handed device independently (box 1) to using a twohanded device to walk alone or with supervision/ assistance (box 2).

While there aren't big changes between the last version of the OASIS C form and the newest one, there are big ones between the OASIS form you're currently using and the one that takes effect Jan. 1, notes consultant Lynda Laff with Laff Associates in Hilton Head Island, S.C."There are so many things that are different and important about OASIS C," Laff stresses.

Chief among these are the new M0 items on processes, Laff says. They address flu and pneumococcal vaccinations; risk assessments for pressure ulcers, falls, and hospitalization; pain assessment and mitigation; heart failure assessment and followup; depression screening; and drug education and intervention.

CMS intends for the new process measure items in OASIS C to improve quality of care and guide home health agencies on how to avoid adverse events, Laff adds.

HHAs should be incorporating these new processes into their operations right now, Friedman Zuber urges. "They should be working hard on their processes so that they can answer the process items affirmatively," she says. "No one wants to be the only agency in the area who isn't screening for depression, falls, etc., and then doing something about it."Hold off on formal training: However, "providers should sit tight and wait for the release of the final version to do any training of staff," Friedman Zuber advises.

Agencies will probably want to wait until CMS issues its item-by-item guidance, formerly known as "Chapter 8" in the OASIS Manual, before undertaking that training, experts say. In its latest Open Door Forum, CMS officials said they expected the new guidance to be out by September or October.