OASIS Alert

Prospective Payment System:

Surprise: For Once It's OK To Use The Wrong Date

Prepare to discard old OASIS forms.

Get ready for assessment chaos in the last five days of 2007.

If agencies could choose, they would avoid admitting or recertifying any patients between Dec. 27 and Jan. 1, industry experts joke. But since patients don't conform to a schedule, some transition planning is important. Prepare now for these three situations:

1. You complete an OASIS assessment in the last five days of calendar year 2007, and the payment episode begins before Jan. 1.

Example: A recertification for an episode beginning between Dec. 27 and Dec. 31.

What to do: To ensure that the grouper software calculates the correct codes, you must enter the date 12/26/2007 in M0090, the Centers for Medicare & Medicaid Services instructs. CMS is temporarily waiving the requirement that you enter the actual completion date in M0090.

2. You complete a start of care or re-sumption of care assessment for an episode that starts between Dec. 27 and Dec. 31, but you don't complete the assessment until Jan. 1.

Example: You admit the patient on Dec. 31, but are unable to get all the information you need to complete the OASIS until the physician's office opens on Jan. 2.

What to do: CMS instructs you to use the temporary waiver and enter 12/31/2007 in M0090 instead of the actual completion date.

3. A patient your agency is caring for is admitted to the hospital and is discharged between Dec. 27 and Dec. 31. The agency must complete the resumption of care assessment within 48 hours, but the next payment episode will begin on or after Jan. 1.

Example: The patient's next episode begins on Jan. 2 and the ROC assessment also acts as the recertification assessment.

What to do: The temporary M0090 waiver applies and you should enter the date 1/1/2008 in M0090, even though you complete the assessment before that date, CMS says.

Resource: For a detailed discussion of these situations, go to http://www.cms.hhs.gov/HomeHealthPPS/03_coding&billing.asp and select "Answers regarding transition episodes."

Out With The Old, In With The New

If you have stacks of old OASIS assessment forms you were hoping to continue using, you're out of luck.

Agencies planning to supplement the old forms with an addendum containing the new and changed items, until they use up their supply of forms, will be disappointed. The changes are too complex for that, confirmed CMS' Pat Sevast at a Nov. 12 OASIS update session held at the OASIS Certificate & Competency Board's annual conference in Baltimore.

CMS addresses this concern in Question 8 of its October Q&As. "The OASIS-B1 1/2008 data set must be used for follow-up assessments as early as Dec. 27, 2007 and all other assessment time points by Jan. 1, 2008," CMS instructs.

Warning: Your staff must be able to access both OASIS datasets during that five-day window, OCCB's Debbie Chisholm stressed. You'll be initiating both 2007 and 2008 epi-sodes during that time.

Note: The new OASIS dataset is available for download at http://www.cms.hhs.gov/HomeHealthQualityInits/12_HHQIOASISDataSet.asp.

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