OASIS Alert

Give each clinician a copy of Chapter 3 if you want to survive the transition.

Get ready to have many of your questions answered. In reply to participants' questions in a recent discussion of OASIS C, CMS's most frequent response was "RTM" -- read the manual -- and it's finally possible for you to do that.

If you've been counting the days left before OASIS C takes effect, you'll be happy to see the document you need for the item-specific staff training. The Centers for Medicare & Medicaid Services posted the long-awaited OASIS C Guidance Manual to its Web site on Oct. 9. This is the most complete version and your agency should be sure you are not using any prior version that may have been available unofficially, CMS says.

The Outcome and Assessment Information Set (OASIS) version C is about to take effect for assessing Medicare and Medicaid patients admitted to home care under the Medicare home health benefit, CMS confirms. The agency declined to delay implementation despite industry concerns about the short time allowed for agency transition after CMS has been working on the project for four years. HHAs have had enough notice; vendors have had sufficient time to prepare; the data set has been available long enough; and CMS is providing sufficient training opportunities to allow for the transition as planned, CMS insists.

Background: OASIS is a set of standard data elements designed to allow comparison of patient outcomes at two points in time. Comparisons are risk adjusted for patient differences to allow more accurate comparison between agencies. In 1999, Medicare-certified home health agencies began collecting and submitting OASIS data on all adult (nonmaternity) patients receiving skilled services with Medicare or Medicaid as a payer source. CMS has revised the OASIS items several times since1999, and will begin using the major revision known as OASIS C on Jan. 1, 2010.

To aid OASIS C implementation, CMS released a new OASIS Guidance Manual on Oct. 9. This manual assumes a basic familiarity with OASIS requirements and contains selected content from the original OASIS Implementation Manual in addition to the new OASIS Cspecific material, CMS says. "Sections relevant to first-time implementation of OASIS data have been deleted," CMS says. Those who need to review these sections or who are new to OASIS collection can review the archived implementation manual at www.cms.hhs.gov/HomeHealthQualityInits/20_HHQIArchives.asp#TopOfPage, CMS instructs.

To allow for easier electronic access and future updates, CMS divided the OASIS C Guidance Manual into five chapters and seven appendices. Agencies can access each of these individually using separate links. All sections can be viewed online or printed. The manual is structured as follows:

Chapter 1 provides introduction and general information relevant to OASIS data collection.

Chapter 2 includes versions of the OASIS C data set for each time point.

Chapter 3 contains item-specific guidance, divided into sections.

Chapter 4 contains sample clinical record forms for OASIS data collection time points.

Chapter 5 includes relevant resources for agencies, many with hyperlinks.

Appendix A explains requirements for integrating OASIS into the comprehensive assessment.

Appendix B sets out information for insuring OASIS data accuracy.

Appendix C includes charts showing how each OASIS item is used: for payment, quality, or risk adjustment.

Appendix D promotes accurate diagnosis coding on OASIS C.

Appendix E has data report regulations.

Appendix F contains instructions on using OASIS for outcome-based quality improvement (OBQI).

Appendix G includes tables comparing OASIS B-1 to OASIS C.

Planning: "The guidance document is critical," a CMS spokesperson tells Eli. "All clinicians doing OASIS assessments need access to the Guidance Manual, either printed or online," the spokesperson advises.

OASIC C changes are extensive. With the exception of tracking items and M0903/M0906, CMS has renumbered all the items. "OASIS B-1 M0 item numbers do not correspond to the new OASIS C numbering scheme,"CMS says in Chapter 1 of the manual. Instead, each section of items is now assigned to a range of numbers. For example, you will find activities of daily living (ADLs) and instrumental activities of daily living (IADLs) in the M1800 and M1900 item numbers.

Chapter 3 of the OASIS C Manual contains item-specific guidance for each OASIS C question. Rather than being a single document, Chapter 3 is divided into 16 sections. Each section covers a specific topic, and is accessible using its own link.

Example: If you want to access information on ADLs and IADLs, first download the entire OASIS C Guidance Manual by going to www.cms.hhs.gov/HomeHealthQualityInits/14_HHQIOASISUserManual.asp#TopOfPage and selecting "OASIS C Guidance Manual" in the Downloads section at the bottom of the page. Then open the downloaded manual and select "Chapter 3". Then select "K" for the section explaining ADL, IADL items.