Medicare Compliance & Reimbursement

Rapid-fire changes to manual keep agencies hopping.

If you think you're up on the latest in OASIS coding, think again.

After posting its June revision to the Outcome and Assessment Information Set (OASIS) Manual last week, the Centers for Medicare & Medicaid Services (CMS) has announced that, in at least two cases, it needs to clarify and correct its new directives.

And more corrections may be forthcoming, warns Lisa Selman-Holman, principal of Selman-Holman & Associates in Denton, TX.

Basics: CMS posted changes to the OASIS Users Manual last week (chapters 1, 2, 4, 5, 8, 9, 10 and 11). The agency has revised about 50 pages in Chapter 8, the section that covers in detail how to answer each of the OASIS questions.

Proceed with caution: So far, CMS and stakeholders have identified two key errors that could steer home health agencies (HHAs) down the wrong path. Both "have considerable potential impact on home health agencies and vendors," cautions the National Association for Home Care & Hospice.

Don't Let Errors Lead To Errors

Be sure your staff reviews the full revision, making special note of these corrections:

• M0175 (inpatient facility). CMS intended in the initial manual revision to clarify how to count the days since an inpatient discharge at the time of recertification.

According to the new instruction, M0175 "identifies whether the patient has been discharged from an inpatient facility within the 14 days (two-week period) immediately preceding the first day of the new certification period."

The problem: CMS inadvertently deleted a reference to "long term care hospital" in the new instructions.

Omission: This statement should be included in the manual update: "If a patient was discharged from a long-term care hospital (LTCH), the correct response is 1." Though CMS plans to make the correction promptly, industry insiders cringed when they spotted a mistake affecting M0175.

In the past, HHAs often mistakenly coded long-term care hospitals as "rehabilitation facilities," since many present-day long-term care hospitals retain the word "rehabilitation" in their names and provide rehabilitation services to their patients. In 2003, CMS set its sights on M0175 coding errors and has since sought numerous overpayment recoveries, leaving many agencies threatened by possible financial setbacks.

• M0245 (payment diagnosis). CMS erroneously altered this OASIS item to include a "severity rating."

Best advice: Ignore the unintended "severity ratings" associated with this item.

Note: To access the Manual changes and monitor subsequent corrections, go to CMS Home Health Agency Center Web site at www.cms.hhs.gov/center/hha.asp.