The Benchmark Email

...benchmarks, strategies and ideas for improving your agency
A service of Fazzi Associates, Inc.

August 15, 2007

Updates and Strategies for
Responding to Proposed OASIS Changes

Question: I understand that the OASIS assessment tool will change because of the PPS model revisions. Do you have information on future modifications to OASIS or ideas on what we need to do to prepare?

Answer: There are two major recommended OASIS changes for which you’ll want to prepare. The first includes suggested changes in the OASIS instrument to accommodate the revisions adopted in the proposed PPS model expected for 2008. These modifications will mostly be related to the new requirements in reporting therapy use and capturing early/late episodes. CMS has posted the proposed OASIS tool that includes revisions reflective of the proposed PPS model. Click here to view CMS’s proposed OASIS tool.

The second recommended change came on Friday, July 27, 2007. CMS published a new proposed OASIS Data Set, OASIS-C, which will eliminate some items, clarify others, and add process measures.

According to CMS, the proposed OASIS instrument includes:

	Elimination of seven original OASIS items not required for payment, quality or risk adjustment,
	Replacement of 44 original OASIS items with items that are revised and/or simplified to respond to industry concerns by increasing clarity and user-friendliness, and/or reducing complexity and burden,
	Seven process items to be collected only at Start of Care/Resumption of Care, four of which are to be asked seasonally (e.g. flu vaccine),
	Ten process items to be collected only at Follow-up, Transfer or Discharge, either seasonally or on a small subpopulation, and
	Thirteen process items to be collected at all OASIS time points, six of which are to be collected on a small subpopulation.

The new OASIS tool will be tested by selected volunteer agencies located in Massachusetts, Colorado, and Ohio. The data collection is scheduled to occur from December 2007 to March 2008. A written report based on data collection and an analysis of the results is due to CMS in September 2008. To access more information on the proposed OASIS-C instrument click here.

What does this mean for agencies? In the July 30th issue of Home Health Line, the CEO of one of the nation’s largest home care agency chains, Keith Myers of the LHC Group, was reported to have told audiences at the NAHC Financial Meeting in Boston “not to wait for the final rule before starting preparations.” Keith is right!

Through Fazzi Associate’s OASIS audits (over 4,600) and hundreds of trainings with agencies throughout the country, we know that the current OASIS instrument has been challenging for many agencies. A team of OASIS experts and consultants at Fazzi Associates is studying both OASIS proposals. Our goal is to identify the best practice strategies and the necessary education for home health agency managers and staff.

If your agency is presently struggling with OASIS accuracy and your average case mix weight at RAP is below the national average of 1.24 or your Medicare profit margins are below MedPAC’s reported national average 16%, you need to do something now. Consider an OASIS audit and training to establish OASIS competency among your staff and managers. If you feel that you have weaknesses in your rehab department, make sure you are utilizing your therapy services appropriately. You are far better off to address these issues now rather than wait until the new regulations are enacted.