Home Health & Hospice Week

While it's not quite time to start training staff on OASIS C yet, you should already be putting into play the new process items from the drastically revamped assessment form.

Latest: The Centers for Medicare & Medicaid Services received Office of Management and Budget approval of the OASIS C data set on July 27, CMS reports on its OASIS C Web site. CMS includes a 64-page crosswalk from the current OASIS B-1 data set to the new OASIS C one that will take effect Jan. 1.

Changes from the 12.2 version of OASIS issued back in March and the 12.4 version approved by OMB are only "minor," notes consultant Lynda Laff with Laff Associates in Hilton Head Island, S.C. (For examples of the changes, see Eli's HCW, Vol. XVIII, No. 27, p. 202.)

Home health agencies at long last have a final OASIS C form to examine, but they still need to hold off on training staff, Laff advises. That's because they'll need the item-by-item guidance in the OASIS User's Manual to complete the training.

CMS plans to issue that guidance in September or October, it said in the most recent home health Open Door Forum.

Get ready: But if you haven't done so already, now's the time to jump into preparation for the process items in the new OASIS C form, Laff urges. Many agencies are focusing on the mechanics of filling out the new assessment form and may be missing the big picture on how all the process items (see story, p. 227) will change the Medicare landscape in terms of quality improvement, surveys, and even reimbursement.

Look to other providers: HHAs wondering how the new process items on pressure ulcers, pain, diabetes, heart failure, depression, falls, medications, and vaccinations will affect them need look no further than hospitals for an example, Laff tells Eli.

Hospitals have been collecting similar process-based data since 2006 and this year -- three years later -- the data is influencing their reimbursement, she points out.

Don't be surprised to see HHA payments affected by process-based outcomes as early as 2011, Laff predicts. "It's so clear what CMS is looking for," she contends -- hard data upon which to base payment.

Agencies should also expect surveyors to begin utilizing process item data, she warns. For example, if a patient undergoes an adverse event related to a fall, you can bet the surveyor will look over the OASIS  assessment to see whether the patient was risk assessed for falls and whether an intervention was implemented in the plan of care. CMS hints at its intentions in its response to OASIS C comments earlier this year. "Agencies that choose not to adopt these evidence-based practices ... will see that decision reflected in their scores for processes measures on the Home Health Compare website," CMS says. "If CMS develops a Pay-for-Performance component to the home health reimbursement system, a decision not to incorporate evidence- based practice could impact payment."

Collecting the data on these process items will be hugely challenging for many HHAs, especially those that do not utilize point of care computer systems, Laff worries. "It's going to be very cumbersome for many home care agencies to manage this process," she says. "This is a major, major change," she warns. Agencies will have to figure out how they're going to collect the pertinent data.

Many staff already have a tough time wrapping their heads around OASIS and its implications, Laff notes. Once the process measures are introduced and the assessment is tied more securely to quality improvement, surveys, and reimbursement, that will only get worse.