Homecare agencies are entering 2010 with an immediate need to implement the new version of the Outcome and Assessment Information Set, known as OASIS-C. Although there were many months available in 2009 for preparation, OASIS-C will have a significant effect on agency operations, most notably due to an expanded focus on agency processes. Implementation will require ongoing oversight and evaluation by agency managers.
General OASIS issues
Although the Conditions of Participation require submission of OASIS data, there have been no sanctions related to discrepancies with data submitted to CMS as compared to the HIPPS code submitted with the final claim. Now, agencies will be required to ensure that the HIPPS code listed on the final claim is consistent with the code sent to CMS via the OASIS submission process. Not only will agencies that do not submit required quality data be ineligible for the market basket update, OASIS submission will now be a condition for payment as well.
Management implications: Evaluate current OASIS submission procedures. Determine the types of error messages the agency receives with its final validation reports and the steps that staff members take to correct them. Question the connection between the validation process and communication to the billing process. At some point in the future, it’s likely that sanctions will be applied pre-payment. The final rule indicates that CMS will communicate future enforcement plans.
Home health quality improvement
As proposed, OASIS submissions will be reconciled with claims data to verify compliance with quality reporting requirements. Also, with the implementation of OASIS-C, 13 new process of care measures will be added to Home Health Compare. Finally, the Consumer Assessment of Health Providers and Systems (CAHPS) will begin during 2010, although this process will not be linked to the payment update (receipt of the market basket update) until 2012.
Management implications: After ensuring basic implementation of OASIS-C, continue to evaluate agency functions related to the 13 new process of care measures (for example, timely initiation of care, influenza immunization received for current flu season, depression assessment conducted). Identify those areas that may be new to the agency, such as use of the depression scale, and ensure that clinicians understand the purpose of the concern in addition to the mechanics of addressing the OASIS data items. Such an approach is necessary to promote appropriate attention to the process itself.
Review the CAHPS requirements (see Homecare Administrator, December 2009), evaluate and select a vendor, and take the necessary steps to prepare for implementation. Agencies are expected to conduct a “dry run” of the survey in the third quarter of 2010, with continuous data collection beginning in the fourth quarter of 2010. Because an agency cannot conduct these surveys without a vendor, and many vendors are already offering training, timely attention to selecting a vendor is a priority for early 2010.
This excerpt was adapted from the article “Clinical and Financial Perspectives for the New Year” by Jane Miles, which originally appeared in the January 2010 edition of Homecare Administrator. Learn more about Homecare Administrator here!
Although the Conditions of Participation require submission of OASIS data, there have been no sanctions related to discrepancies with data submitted to CMS as compared to the HIPPS code submitted with the final claim. Now, agencies will be required to ensure that the HIPPS code listed on the final claim is consistent with the code sent to CMS via the OASIS submission process. Not only will agencies that do not submit required quality data be ineligible for the market basket update, OASIS submission will now be a condition for payment as well.
Management implications: Evaluate current OASIS submission procedures. Determine the types of error messages the agency receives with its final validation reports and the steps that staff members take to correct them. Question the connection between the validation process and communication to the billing process. At some point in the future, it’s likely that sanctions will be applied pre-payment. The final rule indicates that CMS will communicate future enforcement plans.
Home health quality improvement
As proposed, OASIS submissions will be reconciled with claims data to verify compliance with quality reporting requirements. Also, with the implementation of OASIS-C, 13 new process of care measures will be added to Home Health Compare. Finally, the Consumer Assessment of Health Providers and Systems (CAHPS) will begin during 2010, although this process will not be linked to the payment update (receipt of the market basket update) until 2012.
Management implications: After ensuring basic implementation of OASIS-C, continue to evaluate agency functions related to the 13 new process of care measures (for example, timely initiation of care, influenza immunization received for current flu season, depression assessment conducted). Identify those areas that may be new to the agency, such as use of the depression scale, and ensure that clinicians understand the purpose of the concern in addition to the mechanics of addressing the OASIS data items. Such an approach is necessary to promote appropriate attention to the process itself.
Review the CAHPS requirements (see Homecare Administrator, December 2009), evaluate and select a vendor, and take the necessary steps to prepare for implementation. Agencies are expected to conduct a “dry run” of the survey in the third quarter of 2010, with continuous data collection beginning in the fourth quarter of 2010. Because an agency cannot conduct these surveys without a vendor, and many vendors are already offering training, timely attention to selecting a vendor is a priority for early 2010.
Tue, Feb 16, 2010
Billing and Payment