OASIS Alert

Don't get too comfortable. Congressional action could cut rates in near future.

Here's a vital step: Make sure you have the latest -- and most accurate -- version of software and instructions.

The Centers for Medicare & Medicaid Services issued the final home health prospective payment system update on Oct. 30. The final rule implements a 2 percent market basket update, a scheduled 2.75 percent "case mix creep" subtraction, and a new outlier policy that adds 2.5 percent to the base rate. This sets the overall base rate increase at 1.75 percent for calendar year (CY) 2010. The base episode rate for 2010 will be $2,312.94. The low utilization payment (LUPA) add-on will be $94.72.

The PPS rule contains a number of other important items:

• OASIS submission will be a condition of payment. CMS will require providers, prior to submitting a final PPS episode claim, to have submitted an OASIS assessment, and require that the HIPPS code on the final claim match the HIPPS code on CMS' OASIS validation report. CMS has "no intention that this proposed requirement would have an effect on long-standing direction associated with submitting RAPS, OASIS completion timeframes, and instructions associated with one-visit episodes" the agency assures providers.

• Outlier changes will be effective for one year. Efforts to decrease fraud by reducing and capping outlier payments did not change from the proposed rule. "Few HHAs would be negatively impacted with the change," the National Association for Home Care & Hospice predicts.

• Quality data available on Home Health Compare will increase. In CY 2010, CMS "will publicly report 12 nationally accepted and approved quality measures plus 13 new process measures," CMS announces.

• The Consumer Assessment of Healthcare Providers and Systems Home Health Care Survey (HHCAHPS) will begin in 2010. But CMS will delay linking the data to the annual payment update from CY 2011 to CY 2012.

• Even if you have downloaded the CMS data specifications for OASIS C software, you need to download a new copy, CMS'Kim Jasmin announced at the Oct. 21 home health forum. CMS posted HAVEN 9.3 on Oct. 20 at www.cms.hhs.gov/OASIS. Select "data specifications" from the left menu. This corrected version is the third edition of the OASIS C data specs. Refer to file BC200R3 for a list of the corrections. Changes made in the current version are designated as R3.This updated version corrects a few errors in HAVEN 9.2, CMS said in the forum.

Heads up: HAVEN now uses a Javabased grouper, so providers must read the release notes and installation notes prior to installing the new HAVEN program, Jasmin warned.