Home Health & Hospice Week

The wait is nearly over for the drastically revamped OASIS form you'll start using in January.

The federal Office of Management and Budget hasn't approved the final OASIS C form quite yet, Centers for Medicare & Medicaid Services officials said in a June 30 Open Door Forum for home care providers. But this month CMS will issue the all-but-OMB-approved final form in conjunction with new OASIS C data specifications in order to start software vendor training.

The form CMS will issue for the July 15 and 22 vendor training sessions will be "as we project it will be finalized," explained CMS's Pat Sevast in the call that drew 440 participants. Of course, the form could still change pending final OMB approval.

CMS also will issue a comparison of the old and new forms, Sevast said.

"While the form will still be subject to changes until the OMB approval is received, CMS wants to go forward to avoid a protest about the Jan. 1, 2010 implementation," consultant Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C. tells Eli. "Sounds like they are finished with changes for now, unless OMB requires them to make some additional changes," adds Adams, who asked a question about the issue in the forum.

The new form will be pretty close to the final thing if CMS is starting to train vendors on it,expects consultant Betty Gordon with Simione Consultants in Westborough, Mass. "Be very aware of it," she urges about the forthcoming OASIS C form.

Do this: Go ahead and start to make your preparations and plan your OASIS C training based on the form, Adams and Gordon advise. "Make sure it doesn't come down to last-minute scurrying around," Gordon urges.

But be ready to make corrections to your training plan based on the ultimate OMB-approved form CMS issues.

More waiting: Also, much of your training will likely be up in the air until CMS issues its new OASIS User's Manual, which will contain item-byitem guidance (the current "Chapter 8"), Adams points out. CMS expects to issue that document sometime in September or October, Sevast said in the forum.

Other OASIS-related news revealed in the forum includes:

• Home Health Compare and OBQI.

Along with OASIS C, new quality measures -- including process-based measures -- will take effect in January, CMS's Debbie Terkay noted in the forum. CMS plans to generate new risk adjustment models for those measures, which will take some time. The agency also will need to collect data for the measures for a period of time before posting them, Terkay explained.

That means home health agencies are likely to see a six-month-or-so "gray-out window" in 2010 where there aren't updates to Home Health Compare and they don't receive outcome-based quality improvement (OBQI) and monitoring reports, Terkay said.

CMS hopes to post some OASIS C data by December 2010, even if it's only the process-based measures because the risk adjustment models aren't final, Terkay added.

• Attachment D. HHAs are still raising questions about the diagnosis coding guidance CMS included in its Attachment D document. Agencies should code secondary diagnoses that affect the plan of care and patients' response to treatment, Kathy Walch said in the forum. "We rarely see agencies code more than three diagnoses on the OASIS," Walch observed.

Attachment D will get an update when CMS issues the OASIS C User's Manual, Walch added.

• New submission rule. Starting in January, CMS will add another OASIS rule. This one will require all OASIS submissions to have either Medicare or Medicaid marked as a payor on the OASIS form, a CMS official said.

• PPS grouper. HHAs and their software vendors will have two new prospective payment system groupers to deal with in the span of three months, thanks to OASIS C. A grouper update this fall will take into account  the new ICD-9 diagnosis codes that take effect Oct. 1, said CMS's Lori Anderson in the forum. Then a new grouper based on the OASIS C form and scoring will come in January.