Medicare Compliance & Reimbursement

HHAs breathe sigh of relief over last-minute pull-back

If you don't want to transmit OASIS data daily, you'll have to stick with locking OASIS data to achieve timely billing.
 
That's the message of new Centers for Medicare & Medicaid Services (CMS) billing instructions on the new OASIS reporting regulation.
 
Before: In the May 24 Open Door Forum for home care providers, CMS officials said agencies would have to start submitting OASIS data for a patient before billing the request for anticipated payment (RAP) for the patient's episode.
 
That brought loud protests from the industry, because home health agencies would have had to submit OASIS data daily to be able to bill RAPs daily. And agencies' software would have required modification to accommodate the unexpected change.
 
After: Now CMS says agencies can bill RAPs if they "finalize" the OASIS data by continuing to use the lock mechanism, according to the instructions re-leased June 20. Even though the seven-day lock requirement was eliminated June 21, agencies can continue to opt to lock their data on their own schedule instead of transmitting it in order to facilitate faster billing.
 
In other words, "the requirement for agencies to 'lock' OASIS data within seven days will be removed, but agencies may wish to 'lock' data before the 'within 30 days' OASIS transmission requirement in order to file a RAP," the National Association for Home Care & Hospice explains.
 
HHAs have three ways to use the lock date, which is required in the Medicare Claims Processing Manual, according to the CMS instructions:
 
Option 1: Use your non-HAVEN software that locks assessments. If your software has an internal locking feature, continue to use it, CMS advises. "If your software has not been changed in anticipation of OASIS changes, this option will mean no change to your current process is necessary."
 
Option 2: Use the old version of HAVEN (HAVEN 6.2, version 1.40) to lock assessments. This option has a few hitches, CMS notes. Some records will be rejected due to the new consistency checks on ulcers and wounds. However, agencies can correct and resubmit these records. And warnings will result if the agency submits records more than 30 days after the assessment's completion date or if the primary diagnosis code and severity code are inconsistent.
 
Finally, agencies can use the old HAVEN software only until May 2007. That's because Medicare will require National Provider Identifier (NPI) numbers starting then and the software doesn't support NPI submission, CMS points out.
 
Option 3: Use the new version of HAVEN (HAVEN 7.0, version 1.50) and use the optional lock feature for data. "The ability to lock an OASIS assessment has been retained in the new OASIS software," CMS explains in the instructions. "Once data entry for an assessment is completed, the HAVEN Management Screen shows that the assessment is 'Locked (Export Ready)' and a payment group code is available for use on the RAP."
 
Alternate -- Option 4: CMS also acknowledges that some agencies already removed the locking function on their software. Temporarily, these HHAs may "develop internal procedures for establishing that OASIS data is finalized for transmission to the State, equivalent to the prior state of being locked before submitting your RAPs," CMS allows.
 
If agencies use this option, the internal procedure should include the date the OASIS data was finalized, "which could be compared to the dates of submission of RAPs in any future audit of your records," CMS cautions. "As soon as possible you should revise your processes to use one of the compliant options."

More OASIS Changes Required

"I was very relieved to see this information," cheers consultant M. Aaron Little with BKD in Springfield, MO. "This most recent clarification solves the problems created by the earlier instructions."
 
"With the addition of the export status ... OASIS and RAP procedures will be essentially the same as always," adds Abilene, TX-based consultant Bobby Dusek.

Note: CMS' instructions and the HAVEN 7.0 download are available at www.qtso.com. CMS is also sending out HAVEN CDs, it says.