OASIS Alert

Find out how closely your OASIS C form should match CMS'.

Don't bother to print a huge stack of OASIS C forms until the dust settles. You now have another new version to contend with, and questions about the data set form are already rolling in.

The all item OASIS C instrument posted on the government's OASIS C page on Aug. 12 contained errors, the Centers for Medicare & Medicaid Services notified providers. The new version corrects item M1330 (Does this patient have a stasis ulcer?) by adding a fourth option to the possible answers. Originally you could reply that the patient has no stasis ulcer or has at least one stasis ulcer that is either observable or not observable. Now you can also choose, "Yes, patient has BOTH observable and unobservable stasis ulcers."

The corrected form has replaced the Aug. 12 version. The latest data sets for all time points, released Sept. 11, are dated August 2009 at the bottom of each page, according to CMS. (You can download the zip file containing these forms -- "OASIS C Timepoints 200909" -- at www.cms.hhs.gov/HomeHealthQualityInits/12_HHQIOASISDataSet.asp#TopOfPage.)

As home health agencies look closer at the OASIS C data set, questions and answers have started flowing, according to the National Association for Home Care & Hospice (NAHC). Begin collecting these clarifications in one place to answer staff questions as they arise.

One question, for which NAHC reported CMS'reply, addresses how perfect the match must be between an agency's OASIS form and CMS':

Question: We have noticed there are several places throughout the OASIS where there is extra spacing. We are aware that in the past, the instructions were specific in that the verbiage had to be represented exactly as it appears in the OASIS provided by CMS. Can we remove the extra spaces from the verbiage and still be in compliance? Following are a few of the examples of irregular spacing [note characters in bold].

(M0010) C M S Certification Number

(M0016) Branch I D Number

(M0018) National Provider Identifier (N P I)

CMS' Answer: CMS has no problem with agencies/vendors removing the extra spaces as long as they do not have to worry about 508 compliance (Rehabilitation Act of 1973 U.S.C. 794d, Section 508).

"Spacing appears in OASIS C due to a 508 compliance issue -- all documents posted on CMS Web sites must be 508 compliant." So extra spaces were inserted in the OASIS C "instrument" so that screen reader programs would not read [for example] "centimeters" or "id." The spacing is CMS' effort to be 508 compliant by assuring that the non-sighted user will not be misled by what they hear. Clearly, for the sighted reader, it is more correct to have "ICD- 9-CM" and "ID."