CMS Regulatory Update Summary: OASIS Changes, ICD-10 in the Wings

Look for detailed analysis of the following regulatory issues in the January 28 issue of Home Care Automation Report

Summaries by Carolyn Humphrey, RN, MS, FAAN

OASIS Manual, Chapter 8, Attachment D Released
CMS recently released an update to the OASIS manual, “Attachment D: Selection and Assignment of OASIS Diagnosis.” The material updates guidance to home health agencies on implementation of ICD-9-CM coding for case-mix reform that went into effect on January 1, 2008. The document can be found at http://www.oasisanswers.com/downloads/HHQIAttachmentD.pdf

There is concern within the home health industry, with good reason, about the accuracy of these revised instructions and CMS's rationale for the implied policy changes. In next week's issue, we will treat these questions and explore the update further.

Current Status of Proposed OASIS – C
The Centers for Medicare & Medicaid Services is requesting OMB approval to modify the Outcome and Assessment Information Set (OASIS) data set that home health agencies (HHAs) are required to collect in order to participate in the Medicare program.

The January 13th deadline for public comments to the November 14, 2008 Federal Register Notice of Proposed OASIS-C Collection and Comment Request has just past. We will detail next steps in the process in future issues. The document can be found at http://www.oasisanswers.com/downloads/E8-27060_fed_reg_11_14_08.pdf

ICD-10 Final Rule Released
In a decision that gives managers and clinicians a reprieve, HHS has delayed by two years the date to switch all coding implementation from ICD-9 to ICD-10. The final rule has been released but it moves the deadline back from October 1, 2011 to October 1, 2013. 

Preparation for ICD-10 by clinicians and software companies will take considerable time and effort as the new system will contain almost 10 times as many codes as ICD-9. To help providers prepare for the ICD-10, CMS sponsored an educational conference call on November 12th which included an overview of ICD-10 along with implementation recommendations and resources. A transcript of the conference call is available on the CMS website: http://www.cms.hhs.gov/icd10/Downloads/Nov12calltranscript.pdf
A PowerPoint presentation was also given and can be accessed from the CMS website: http://www.cms.hhs.gov/ContractorLearningResources/Downloads/ICD-10_Overview_Presentation.pdf

According to an estimate included in HHS's proposed rule, implementing ICD-10 changes will cost the healthcare industry approximately $3 billion, with costs continuing well into 2017. The agency also estimates that ICD-10 benefits will approach $4.5 billion between the second and twelfth years after implementation. The code set can be found at http://www.cms.hhs.gov/ICD10/01m_2009_ICD-10-PCS.asp#TopOfPage

Conference call presenters recommended that organizations begin planning now for how the ICD-10 will be transitioned into their current systems. In next week’s HCAR, we will provide more detail and analysis about both OASIS changes and the ICD-10 final rule.

HIPAA Privacy Rule Guidance Issued
The Office for Civil Rights, the government agency responsible for oversight of the Health Insurance and Portability and Accountability Act (HIPAA) privacy rule requirements, issued new guidance on how the rule can facilitate electronic exchange of health information. This new guidance is laid out in a series of questions and answers on the Department of Health and Human Services website.

©2009 by Carolyn Humphrey and Home Care Automation Report. Reprints by permission only. Carolyn Humphrey is president of Humphrey Associates, Louisville, KY and the former editor of Home Healthcare Nurse Journal.