Home Health & Hospice Week

Get cracking on your OASIS C preparations.

You can get a sneak peek at the final OASIS C form.

The Centers for Medicare & Medicaid Services has posted a link to the form for Office of Management and Budget approval at www.cms.hhs.gov/HomeHealthQualityInits/06_OASISC.asp.

CMS took comments on the latest version of OASIS C until Jan. 13, it notes on its OASIS C Web site. CMS “has completed its review and response to comments resulting in a revised final version 12 of OASIS C,” the agency says.

Deadline looms: CMS will put the form through proposed rulemaking this spring, it says. The deadline for final implementation continues to be Jan. 1, 2010 -- less than nine months away. The new OASIS C tool has 14 deleted OASIS items compared to the November version, six new items, and 21 items that contain rewording ranging from minimal to additional scoring options to overall changes, says consultant Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C.

Among the changes, CMS listened to complaints from providers about the new items on date of referral and start of care. First, CMS flipped the items, so M0102 now refers to the referral date and M0104 now refers to the SOC date.

In the last OASIS C version, M0102 said, “Indicate the date the physician made the referral for this home health Start of Care (Resumption of Care).” Now the new version at M0104 says, “Indicate the date that the written or documented orders from the physician or physician designee for initiation or resumption of care was received by the HHA.”

This responded to a criticism from the California Association for Health Services at Home and others. The old item needed to “differentiate between an inquiry about services and an actual referral for services,” CAHSAH noted in its comment letter on the form. Also, “not all referrals come from a physician,” so the old item needed to not limit referrals to docs only, CAHSAH told CMS.

Now that the final OASIS C form is out, barring a few final tweaks due to rulemaking, agencies need to get serious about planning their OASIS C preparation strategies, experts urge.

Note: For a free PDF copy of the new OASIS C form, e-mail editor Rebecca Johnson at  www.rebeccaj@eliresearch.com with “OASIS C March” in the subject line. For in-depth analysis of the changes in the final OASIS C form, see future issues of Eli’s Home Care Week.