Home Health & Hospice Week

If you've been working hard to bring your staff up to speed on OASIS C, you don't want to overlook one important step -- providing them with the source material for item-specific guidance.

The Centers for Medicare & Medicaid Services posted the long-awaited OASIS C Guidance Manual to its Web site back in October. The agency declined to delay OASIS C implementation despite industry concerns about the short time allowed for agency transition after CMS has been working on the project for four years.

Home health agencies had enough notice; vendors had sufficient time to prepare; the data set has been available long enough; and CMS has provided sufficient training opportunities to allow for the transition as planned, CMS insisted.

Background: In 1999, Medicare-certified home health agencies began collecting and submitting OASIS data on all adult (nonmaternity) patients receiving skilled services with Medicare or Medicaid as a payer source. CMS has revised the OASIS items several times since 1999.

The new OASIS C Guidance Manual assumes a basic familiarity with OASIS requirements and contains selected content from the original OASIS Implementation Manual in addition to the new OASIS C-specific material, CMS says.

"Sections relevant to first-time implementation of OASIS data have been deleted," CMS says.

Those who need to review these sections or who are new to OASIS can review the archived implementation manual at www.cms.hhs.gov/HomeHealthQualityInits/20_HHQI Archives.asp, CMS says. The new manual is at www.cms.hhs.gov/homehealthqualityinits/14_hhqioasisusermanual.asp.

To allow for easier electronic access and future updates, CMS divided the OASIS C Guidance Manual into five chapters and seven appendices. Agencies can access each of these individually using separate links. All sections can be viewed online or printed. The manual is structured as follows:

Chapter 1 provides an introduction and general information relevant to OASIS data collection.

Chapter 2 includes versions of the OASIS C data set for each time point.

Chapter 3 contains item-specific guidance, divided into sections.

Chapter 4 contains sample clinical record forms for OASIS data collection time points.

Chapter 5 includes relevant resources for agencies, many with hyperlinks.

Appendix A explains requirements for integrating OASIS into the comprehensive assessment.

Appendix B sets out information for insuring OASIS data accuracy.

Appendix C includes charts showing how each OASIS item is used: for payment, quality, and/or risk adjustment.

Appendix D promotes accurate diagnosis coding on OASIS C.

Appendix E has data report regulations.

Appendix F contains instructions on using OASIS for outcome-based quality improvement (OBQI).

Appendix G includes tables comparing OASIS B-1 to OASIS C.

Planning: "The guidance document is critical," a CMS spokesperson tells Eli. "All clinicians doing OASIS assessments need access to the Guidance Manual, either printed or online," the spokesperson advises.

And don't forget the list of corrections that CMS already has made to the manual, which is under the "OASIS C Guidance Manual Errata" link on the manual page. It has 10 pages of corrections that CMS has made to the document already.

Note that the changes are to the manual guidance, not the OASIS instrument itself, CMS reminded callers in the Dec. 2 Open Door Forum for home care providers.

At some future point, CMS will issue a revised manual that includes those corrections, an agency representative said in the forum.

OASIC C changes are extensive. With the exception of tracking items and M0903/M0906, CMS has renumbered all the items. "OASIS B-1 M0 item numbers do not correspond to the new OASIS C numbering scheme," CMS says in Chapter 1 of the manual. Instead, each section of items is now assigned to a range of numbers. For example, you will find activities of daily living (ADLs) and instrumental activities of daily living (IADLs) in the M1800 and M1900 item numbers.

Chapter 3 of the OASIS C Manual contains item-specific guidance for each OASIS C question. Rather than being a single document, Chapter 3 is divided into 16 sections. Each section covers a specific topic and is accessible using its own link.

Example: If you want to access information on ADLs and IADLs, first download the entire OASIS C Guidance Manual by going to and selecting "OASIS C Guidance Manual" in the Downloads section at the bottom of the page. Then open the downloaded manual and select "Chapter 3." Then select "K" for the section explaining ADL, IADL items.