Implementation of new OASIS-C (Outcome and Assessment Information Set) requirements starts January 1, 2010. Some of the revisions from OASIS-B1 are extensive. As anyone with experience in this industry can tell you, failure to understand or submit data correctly may reduce Medicare payments to your agency.
Despite testing and an extensive review process, the Centers for Medicare and Medicaid (CMS) changed the most recently updated version of OASIS-C regulations published on September at the NAHC (National Association for Home Care) conference in mid October.
“CMS had already issued item-by-item guidelines ahead of the OASIS conference,” explained Lisa Selman-Holman, president of Selman-Holman & Associates and an expert on home care and hospice issues. “However, there were so many questions and requests for clarification in the OASIS Coordinators’ Conference, CMS had to step back, review and reissue the guidelines. They have provided even more clarification since then in the form of Q and As.”
Selman-Holman has extensive experience with OASIS requirements. She is leading Ultimate OASIS-C Item by Item training, which incorporates even these most recent CMS changes. HCAR caught up with Selman-Holman at the OASIS Certificate & Competency Board Conference in Baltimore this week. She provided an overview of the most dramatic shifts from earlier OASIS versions.
Additional process measures
“OASIS-B1 included outcome measures that looked at changes in patient condition over time,” said Selman-Holman. “Process measures look at how you implemented best practices, regardless of patient status. For example, consider heart failure. Originally, you had to report the patient’s condition at the end of care. Was it better, worse or the same? Now, if you identify a patient as having heart failure, OASIS-C requires you to document what you did about it and how you incorporated best practices in the patient’s care. You still have outcome measures in OASIS-C. CMS just added another level of questioning.
“These new process outcomes are going to be very important to your agency’s best practices. Some of them are optional, but your best bet is to be prepared because CMS will publicly report some of the measures.”
Pressure Ulcer Data Items
Selman-Holman says CMS has completely revised the pressure ulcer data items and OASIS-C includes many more questions than earlier OASIS versions.
“Much more detail is required for pressure ulcers,” she said. “The guidance is confusing. The data required depends on the stage of the wound. You really have to pay attention to what’s being asked.
Addition of grids
CMS has replaced some previous questions with grids in OASIS-C. Selman-Holman says these grids potentially make it easier for clinicians to answer items more accurately. For example, in OASIS-B1, clinicians were required to estimate a patient’s capabilities on the 14th day of treatment. CMS deleted these questions and replaced them with a grid that asks you to record the patient’s level of independence prior to his or her illness, injury or exacerbations.
“This is a big change,” Selman-Holman said. “However, it will make it easier to complete OASIS-C.”
OASIS-C also includes major changes in the area of wound care. In response to confusing wound classification terms, CMS will follow the Wound Ostomy Continence Nurses Society’s (WOCN) recently revised Guidance Document, OASIS Skin and Wound Status M0 Items.
Selman-Holman offers additional advice on the new process measures and on preparing to implement OASIS-C.
“The process measures require standard assessment tools, which most home health agencies already use. Make sure your assessment tools meet the Medicare criteria. If they do, you won’t have to make any changes. If they don’t, choose a different assessment tool. I recommend you start using the new tool now so your staff does not have such a big learning curve in January when OASIS-C takes effect.
“Furthermore, if a patient’s transfer or discharge occurs after the effective date for OASIS-C and you instituted best practices before January 1, you can take credit for the process measure.
“There’s a lot to learn here,” Selman-Holman continues. “You can’t learn everything in one huge class. With Ultimate OASIS-C training Item by Item, you can complete the training in modules.”
Ultimate OASIS-C Item by Item online assessment and coding instruction
What: Series of stand-alone video modules with accompanying handouts
When: Available early November 2009
Who: Lisa Selman-Holman and MedPass
Lisa Selman-Holman JD, BSN, RN is the founder of Selman-Holman & Associates, a home care and hospice consulting agency. Lisa is certified as a Homecare Coding Specialist Diagnosis (HSC-D) and in OASIS competency (COS-C).