Is your Home Care Agency Ready for the Changes Being Implemented in CY 2015?

Each year, many Americans desire change and create annual New Year’s Resolutions, however, this year if you work in the Home Health Industry, resolution or not, change is coming! The first major change in the industry is the process for submission of OASIS documents and the second is OASIS-C metamorphosis into OASIS-C1/ICD-9. CMS has been working diligently to ensure all systems are go with the new processes and are hoping the impact and downtime is minimal. Let’s take an in depth look at what is changing and the rationale behind each.

The end of 2014 will see the extinction of agencies submitting OASIS data to CMS through stage databases. Beginning January 1, 2015, agencies will begin submitting data directly to CMS via the new Assessment Submission and Processing System (ASAP) system. To transition data from state databases, the OASIS submission system will shut down permanently at 6:00 PM ET on 12/26/14 and the OASIS ASAP system will begin accepting assessments at 12:00 A.M. on 1/1/15. No OASIS assessments will be accepted from 6:00 PM on 12/26/14 through 11:59 PM o 12/31/14.

 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: MDS (nursing homes) or CARE tools; depression screening (NQF); and acute care hospitalization. CMS also had a desire to decrease the paperwork burden of data collection. OASIS-C1 was scheduled for release with implementation of ICD-10-CM in October 2014, however, with the delay of ICD-10-CM came an interim OASIS version – OASIS-C1/ICD-9.

  • Current OASIS data set (OASIS‐C) will remain in effect until 11:59:59 p.m. on December 31, 2014.
  • OASIS‐C1 / ICD‐9 will go 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. In order to correctly determine which assessment must be used, you will need to take a look at the M0090 date (Date Assessment Completed). 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, 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 OASISC 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 OASISC1/ICD9 data set must be completed instead of the OASISC.” (CMS Quarterly Q&A, Category 4a #1, 07/2014)

Some OASIS-C changes 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 C1/ICD9: 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.

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, and 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 upcoming changes expected to impact the agency and 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. Even if you’ve educated staff, continued education and reinforcement will be the route to success!

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