Each year, in a desire to change, many of us create annual New Year’s resolutions. However, 2015 has brought change for the Home Health Industry, resolution or not! The first major change in the industry is the process for submission of OASIS documents, and second is the OASIS-C metamorphosis into OASIS-C1/ICD-9.
CMS has been working diligently to ensure all systems are prepared with the new processes and is hoping the impact and downtime is minimal, though there have already been reports of some submission denials. With the new OASIS data set and implementation of the CY2015 Final Rule, if your agency is relying on coding alone to achieve “case-mix average,” you will need to make some significant changes.
As of January 1, 2015, the OASIS assessment is being submitted directly to CMS through the Assessment Submission and Processing System (ASAP). According to the minutes of an OASIS Software Developer Vendor conference call (Oct., 2015), this change was made to enable web services that allow faster responses, enhanced interactive capabilities, and mid-process changes in data entry.
You may be asking yourself, “Why the Revision of OASIS-C?” The most concise response is the need to increase continuity of OASIS items and quality outcomes with other data sets and tools. These include MDS (nursing homes) or CARE tools, depression screening (NQF), and acute care hospitalization. CMS also desires to decrease the paperwork burden of data collection. OASIS-C1 was scheduled for release with implementation of ICD-10-CM in October 2014, however, the delay of ICD-10-CM brought an interim OASIS version: OASIS-C1/ICD-9.
- OASIS‐C1/ICD‐9 went into effect at 12:00 a.m. on January 1, 2015 and shall remain in effect until ICD‐10 is implemented, or until another disposition is made by CMS.
The M0090 date for all assessments will determine which version of the OASIS must be completed this month. If the Date Assessment Completed is 12/31/14 or before, agencies will need to use the OASIS‐C data set. However, if the Date Assessment Completed is 01/01/15 or after, agencies will use the OASIS‐C1/ICD‐9 data set. CMS published a Q&A to clarify which assessment is appropriate: “If an assessment is completed on or before 12/31/14 utilizing the OASIS‐C data set and the assessing clinician chooses to reassess one or more OASIS items on or after 01/01/15 during the allowed timeframe for data collection (for example: within 5 days after the SOC, within 2 days after the ROC or DC), this would change the M0090 date and the OASIS‐C1/ICD‐9 data set must be completed instead of the OASIS‐C.” (CMS Quarterly Q&A, Category 4a #1, 07/2014)
Taking a look into specific changes, you will notice some were significant while others had simple rewording or modification of words. Several OASIS-C items were deleted altogether and a few items were added.
- Substantive changes:
- – M1033, M1309, M1910, M2250
- Other changes include:
- Updating of clinical concepts
- Modifying item wording
- Deletion of unnecessary wording such as “non‐epithelialized” in M1307
- Changing of word order
- Adding clarifying terms – adverse (M2000), nonadherence (M2002), non‐agency caregiver (M2102), significant (M2000)
- Modifying responses to improve clarity ‐ immunizations
- Re‐ordering response instructions, adding guidance from Q&As
- Deleted Column 2 in M1308.
- M1309 Worsening in Pressure Ulcer since SOC/ROC added to “harmonize” with MDS (nursing home) and CARE (post acute hospitalization) tools.
- M2250d Depression intervention – added intervention for reporting to physician of a positive depression screen to qualify for an NQF measure
- Deletions in C‐1/ICD‐9
- M1012 (Inpatient Procedures)
- M1310, M1312, M1314 (Stage III and IV Pressure Ulcer Measurements)
- M2440 (Reasons for Nursing Home Admission)
- Time Point Deleted at Discharge
- M1350 (Skin Lesion or Open Wound)
- M1410 (Respiratory Treatments)
- M2110 (Frequency of ADL or IADL Assistance)
- (M1309) – New Item in C‐1/ICD‐9: Worsening in Pressure Ulcer Status since SOC/ROC:
- M1309 replaces Column 2 in M1308 and was created to harmonize the reporting of pressure ulcers that have gotten worse since the most recent SOC/ROC with the MDS (nursing home) and CARE (post acute hospitalization) tools.
Right now, you should be asking yourself how all of this could impact your agency. These changes alone may not place a burden on your agency. However, when combined with the CY 2015 Final Rule (which removed case-mix points from approximately 170 diagnoses as well as OASIS items), if clinicians are not taking time to complete a thorough assessment on patients and physician documentation isn’t specific, the potential to lose reimbursement monies has increased. If the patient was assessed using a validated, standardized falls risk tool and was found to be at risk, it is more imperative than ever to ensure all functional items on the OASIS C-1 are being addressed correctly AND therapy utilization in M2200 is correct before submitting your Request for Anticipated Payment (RAP) to CMS.
If the patient is a fall risk and all functional OASIS items are changed appropriately to indicate the patient is not safe ambulating without assistance of device or person (as appropriate), your functional score will most likely be a 2. If you have a high utilization of therapy, it now takes fewer points to gain a step. Be careful that therapy isn’t being over-utilized, as this new model may be CMS’ way of determining which agencies need to be targeted for audit.
Overall in the dataset, there are:
- 5 deleted items: M1012, M1310, M1312, M1314, and M2440
- 6 new item numbers (but only ONE new item)
- 48 item wording changes
- 6 skip pattern changes
- 3 items no longer collected at discharge: M1350, M1410 and M2110.
If you haven’t already, I encourage you to educate all staff members on these changes, as they are expected to impact agencies and the industry. Data and billing specialists, administrative staff, and others need to know the new process for OASIS submission and each agency member needs to be aware of the updated OASIS-C1/ICD-9.
Education is key when completing the OASIS C1! Even if you’ve educated staff, continued education and reinforcement will be the route to success!