Advanced Search

Home Health & Hospice Week

OASIS:

GET READY FOR A LOT OF OASIS-C WORK

Published on Tue Jan 20, 2009

CMS underestimates burden of revamped patient assessment tool, industry reps charge.

OASIS-C is getting the cold shoulder from many home health agencies, and one of the biggest complaints is the extra work it will entail.

The Centers for Medicare & Medicaid Services proposed the latest OASIS-C incarnation in the Nov. 14, 2008 Federal Register. In supporting paperwork, CMS claims that the new form will add no additional workload for HHAs beyond brief initial training.

The OASIS-C form will have more M0 items, but some of them won't apply to all patients,CMS maintains. "For example, there are a number of questions related to pressure ulcers that apply only to the home health population with pressure ulcers, estimated to be less than 5 percent," the agency says.

None of the data CMS collected while field testing the tool "indicates that any additional time would be required to complete the OASIS-C," CMS contends. "Clinicians who participated in the field testing reported that the OASIS-C took about the same time to complete as the OASIS-B1."

Many of the new items "collect information that home health agency clinicians were already collecting in the course of their comprehensive assess ment (e.g., pain assessments or falls risk assessments)," CMS says. "Recording the information on the OASIS did not require additional time."

Bottom line: Training on OASIS-C will take four hours per staff member, CMS estimates. After that, the usual eight hours per year for each HHA should cover the OASIS training burden. CMS allocates no additional burden for filling out the longer OASIS-C form.

CMS's burden estimate is "grossly inadequate," the Connecticut Association for Home Care & Hospice charges in its OASIS-C comment letter submitted last month. "Agencies invest significant time and resources in both initial and ongoing training regarding accurate completion of OASIS assessment items, since these assessments are vitally important to quality reporting and payment for each agency," CAHCH stresses.

"We feel the changes will substantially increase the burden," says Joe Hafkenschiel with the California Association for Health Services at Home. "Everyone I have talked to agrees," Hafkenschieltells Eli.

The National Association for Home Care & Hospice calculates that filling out OASIS-C will take clinicians an extra 30 minutes beyond the current time for OASIS-B1, it says in its comment letter.And start-up training will take eight hours per staff member, not four, NAHC believes.

Ongoing OASIS training costs HHAs two hours per clinician per month, not the eight hours per agency per year that CMS estimates, NAHC adds.

Staff turnover adds to that burden too, CAHSAH points out in its comments. "Each time a new clinician is hired, they must be trained on OASIS."

Hidden cost: The burden estimate also "does not account for the costs that [HHAs] will incur to implement computerized or manual systems to harvest information needed for transfer and discharge assessments related to process interventions implemented during the course of care," NAHC adds.

Agencies are concerned they will have "yet more OASIS items to deal with and pressures to do more with less," concludes Bob Wardwell with the Visiting Nurse Associations of America.

Overlooked: Many HHAs will spend extra time to put in place policies, procedures, and tools to support the new process measures. "There will be increased time involved in actually implementing the processes called for," Wardwell predicts. "The demands to do more and document more in reaction to process measures could require more to be donethan is always necessary," he fears.

Patient backlash: HHAs aren't the only ones getting fed up with the increasing administrative burden. "Patients are beginning to complain about the documentation requirements for home health," says Marcia Tetterton with the Virginia Association for Home Care and Hospice.

Hold Off, Reps Exhort

Given the significant additional burden and the confusion surrounding some of the new M0 items, some industry representatives are calling for CMS to delay OASIS-C implementation. The new tool is currently set to take effect Jan. 1.

"The implementation should be delayed or reconsidered altogether," CAHCH urges in its comment letter.

At least, "before proceeding with implementing OASIS-C, we recommend that CMS further field test the proposed instrument and collect accurate data on the burden of the proposed changes," CAHSAH says.

Or wait until Medicare's Continuity Assessment Record and Evaluation (CARE) instrument is online, since CMS will expect all post-acute care providers to use it too, CAHCH recommends. CMS field tested the CARE tool last year.

Don't hold your breath: HHAs shouldn't count on any delays, however. There is "a sense of resignation that OASIS-C is essentially a donedeal," Wardwell believes.

Note: For details on the OASIS-C M0 items agencies would like to see changed, see future issues of Eli's Home Care Week.

Other Articles in this issue of

Home Health & Hospice Week

View All