OASIS-Central

When the Centers for Medicare and Medicaid Services (CMS) released the first version of the revised OASIS, Beacon Health feared the incorporation of process data elements would create problems. It looks as though our fears have come to fruition. The very presence of these questions is driving agencies to change processes, which, in too many cases, is creating turmoil and extra work.

Let’s back up and look at the facts behind the process measures and then determine a rational approach.

Fact: An agency does not have to modify its processes to incorporate the evidence-based practices (EBP) in OASIS-C.

In the OASIS-C Guidance Manual instructions for every one of the EBP data elements, CMS notes, “The best practices in the item are not necessarily required in the Conditions of Participation.” In its response to public comments in March 2009, CMS said an agency is not required to modify its processes to incorporate these process measures. If the best practice is not appropriate for the agency, the data elements offer a response option, “No.”

Fact: Checking “No” to indicate that something was not done is allowed.

CMS also said that staff can opt out by responding that the screening was not done, the interventions not planned or implemented.

Fact: Public reporting will not have as big an impact as some agencies believe.

Even though these processes are optional, some agencies feel pressured to move forward with every EBP because CMS plans to report process measures through Home Health Compare (HHC). They don’t want to be viewed as not caring when CMS reports the results through HHC. An agency will receive Outcome-based Quality Improvement (OBQI) reports on 47 process measures. However, beginning in October 2010, HHC will report only five process measures addressing implementation of EBP: treatment of pain, heart failure, and pressure ulcers; diabetic foot care; and medication education for short-term episodes only. These are measures that homecare clinicians routinely tackled before OASIS-C, so an agency shouldn’t have to do much except some fine-tuning. The public will not see the results for the controversial elements, such as the one-calendar-day notification of the physician about medication issues.

Fact: HHC will not report every process measure an agency implements.

Even the most conscientious agency won’t score 100 percent on its HHC reports for the five publicly reported measures. With the instructions for collecting and reporting data that CMS has put in place, some of the processes an agency implements won’t be captured. HHC will report results for short-term episodes only. That episode is 60 days or less from start or resumption of care through transfer or discharge, with no recertification involved. Data collection twists can overlook the implementation of a process. In this example, the implementation of two processes will be lost. Example: The nurse taught the patient diabetic foot care during the first week of the episode. On day 56, she recertified his plan. In the first week of the new episode, the nurse taught a new family member about foot care. One week later, the patient was discharged. The recertification assessment does not include M2400, invention synopsis, so the education in the first episode is not captured for OBQI. The discharge assessment does ask, so the agency’s OBQI report will include the education of the caregiver in the second episode.

However, when the patient was recertified, the episode no longer qualified for public reporting because it was considered long-term.

Fact: The agency, not CMS, initiates best practices.

The agency’s leadership team must identify the quality improvement measures, including best practices, that will benefit its patients. For example, if an agency’s patient population is at low risk for pressure ulcers, it can defer implementation of those best practices and focus on something with greater urgency.

This is an excerpt from the article “Facts about OASIS-C Process Measures Restore Common Sense” by Diane Omdahl, which originally appeared in the February 2010 edition of Homecare Direction. Learn more about Homecare Direction here!