In their document OASIS-C:
Public Comments and Responses,
CMS indicates this item will be used for
risk adjustment and to calculate the publicly-reported
measure on depression screening. We expect
that CMS will provide guidance when the
OASIS C Guidance Manual is released later
this year regarding how to respond to this
item when a person is unable and to also
define “unable”. Currently,
all outcomes are not calculated for all
patients based on certain criteria. Perhaps
the inability to respond will be a consideration
as well. We do not know at this time.
2. When
will OASIS-C take effect?
The projected time point for implementation
is January 1, 2010
3. Do
we know which questions will be asked at
which OASIS time points?
Page 3 of OASIS C, version 12.2, contains
the list of items that will be asked at
each time point.
4. How
are the nurses/therapists going to be able
to complete this lengthy assessment within
the current time frames?
CMS has responded to this question beginning
on page 3 of their document OASIS-C:
Public Comments and Responses.
CMS did conduct field testing on the time
spent in the home collecting OASIS C data
and the time spent outside the home collecting
additional needed data. This included only
OASIS C items and not the entire assessment
process. They concluded there is minimal
additional time burden related to collecting
these items compared to the current OASIS
B1 items. Are you surprised? However, we
do expect there will be more time spent
initially especially until clinicians become
familiar with the new tool. As we recommended
in the webinar, we suggest you expose your
clinicians to the tool early and begin to
identify ways to modify your current workflow
and communication channels so that the burden
on the assessing clinician is minimized.
5. Do you
have any suggestions for re-educating clinicians
and when should the education begin?
We recommend the education of your clinicians
begin now. Consult our OASIS
Complete Resource Page for information.
Show them OASIS
C 10 Facts in 10 Minutes and share
the draft tool with them.
6. Has
there been any consideration that this is
being implemented over a holiday period
when resources are less?
We recognize how close the implementation
is to a major holiday period. We recommend
you begin preparation now.
7. Will
we be getting a list of the high risk medications?
CMS plans to provide further guidance on
responding to this item in the OASIS C Guidance
Manual and on what are considered “high-risk”
drugs, including links to well-established
high risk medication lists such as JCAHO,
the Beers Potentially Inappropriate Medications
for the Elderly criteria, and the Institute
for Safe Medication Practices “High
Alert Medication List.”
8. Is
there no risk assessment for pressure ulcers?
What about a pain measurement instrument?
Or a falls risk assessment?
CMS does not require agencies to conduct
a pressure ulcer risk assessment, falls
risk assessment or a pain assessment, and
does not wish to specify assessment tools.
Rather, agencies are encouraged to use the
tools of their choice when they determine
it is appropriate to do so. CMS does plan
to use these items in future OBQI/OBQM reports.
There is clinical evidence that patients
do benefit when these tools are utilized
appropriately. We would recommend that agencies
look at their current policies and practices
related to these standard assessments and
investigate the consistency with which interventions
are initiated for follow through.
9. One
comment I would make is that I do not believe
if the referral is for physical therapy
only the PTs will have issues addressing
items they perceive are designed more for
a nurse.
Interestingly, not all therapists share
that opinion. In fact, the APTA has identified
that the OASIS C items are within the scope
of physical therapy practice, although a
few may be restricted by individual state
practice acts. We have posted the written
comments from the APTA here.
We recommend that therapists be included
in all training related to the completion
of the current OASIS and the new OASIS C.
Just as with nursing, therapy competence
with completing the OASIS data affects both
reimbursement and outcomes.
10.
Will the RN have to do all the admissions
for OASIS-C?
There is no federal regulatory requirement
for nurses to do all admissions. The American
Physical Therapy Association confirms the
ability of physical therapists to perform
comprehensive assessments unless the states
practice act limits that ability.
11.
The first initial comment period ended on
or around Jan 19th, 2009. This is the second
comment period as required by posting in
Fed registering if I understand correctly.
Would you anticipate any major changes as
result of this second comment period?
In our humble opinion, we expect to see
some “tweaking” but no major
changes to the content of the OASIS C document.
12.
What is your stand on POC versus a paper
system for collection of data?
Each method has its strengths and weaknesses.
We are unable to respond with more detail.
13.
When do you anticipate this will be implemented
for Hospice Care?
We do not know, but with each change CMS
makes for Hospice, you can see the time
growing shorter!
14.
When will there be a class available for
OASIS C certification?
We at Fazzi Associates are working towards
a program which identifies agencies as an
OASIS Center of Excellence. Stay tuned!
15.
When would you anticipate OASIS-C content
being in the OASIS NP product?
We have been providing glimpses of OASIS-C
in our current OASIS
NP product. OASIS-C will be fully integrated
once the final version and the guidance
document is released later this year.
16.
Why would nurses want to work in home health
and have to work with all this paperwork?
We empathize with your comment. Since agencies
are going to have to redo their forms one
more time, we recommend you also take a
good look at your forms and look at where
you might reduce the paper burden. What
information should a meaningful and comprehensive
assessment gather? Revise them to delete
any areas that are duplicated and delete
any areas that are not being used and are
not needed to meet regulatory requirements.
Make them more users friendly. We think
clinicians would love to be involved with
a project that could cut down on documentation
time!
17.
Will a recap of the polling items be available?
Where will we find the responses?
18.
Where can we find the depression screening
tool recommended by CMS?
The PHQ-2 is imbedded in the OASIS-C tool
as item M1730. CMS will provide more information
in the OASIS-C Guidance manual. You can
also do an internet search for more information.
19.
What changes on OASIS-C will impact reimbursement
- negatively or positively?
CMS tells us that the OASIS-C instrument
is not expected to affect payment. The grouper
information will be published later this
year and we will post it to the OASIS
Complete Resource Page when it is available.
20.
Has CMS considered not using OASIS-C for
long term MediCaid Waiver clients, since
it truly does not apply to those clients?
We currently must collect the data, but
it has no meaning.
We do not have an answer for this question.
21.
How can OASIS data be accurately risk adjusted
without consideration of educational level
and income?
We are unable to respond to that question.
However, M0150 Payment Source from the current
OASIS B1 is a risk factor relevant to some
outcome measures.
22.
Could you work with NAHC and the WOCN association
to promote foot care assessment tool and
care plans? And do you have a recommended
foot care assessment tool?
An internet search provided this article
- Diabetic
Foot Ulcers: Prevention, Diagnosis and Classification
- with a simple monofilament test for the
risk of developing neuropathic ulcers.
The American Diabetes Association is a
good source of information for foot care.
CMS will provide links to resources
in the OASIS C Guidance Manual.
23.
Is a recording of this webinar going to
be on the Fazzi website?
Here is the link
for “OASIS-C 10 Facts in 10 Minutes”
24.
Is the current OASIS-C draft version 12.2?
Yes. Version 12.2 was released in March
2009.
25.
Medications are a huge challenge for everyone,
but especially for non-nursing staff. Are
there some good ways to handle this medication
issue, especially when there are patients
with only therapy services?
The MedQIC
Website has information for medication
management. In our experience, those agencies
that have had good experiences with this
issue have provided tools and communication
avenues for all disciplines and have nurtured
a culture of collaboration between nursing
and therapy so this issue is managed as
a team and not an individual discipline.
We plan to make this a topic for a future
webinar. Stay tuned!
26.
Some of the questions involve staff going
into patient records and auditing care and
effectiveness of interventions used to date.
We question whether this is the intent of
an assessment form.
OASIS is part of an assessment form, but
is more correctly labeled as a data collection
tool. It was initially developed as a dataset
for measuring and reporting quality. CMS
is committed to developing and publicly
reporting process measures that support
evidence-based practices and give credit
to the agencies that adopt them. CMS determined
that integrating the process items needed
to support these new measures into the OASIS
data set is the least burdensome method
of collecting the data from home health
agencies. We agree that the addition of
these process items will create an added
burden to agencies and clinicians as evidenced
by the response to the polling question.
We have passed along the information to
CMS. We recommend agencies work closely
with software vendors to find electronic
assistance and begin to work on work flow
issues and tools to assist in the information
gathering.
27.
Does CMS have specific evidence-based research
that they have used in building expectations
for the processes and outcomes they are
looking for? If yes, will CMS be making
the specific info available?
In OASIS-C:
Public Comments & Responses,
CMS indicates that panels of technical experts,
stakeholders, industry associations, professional
organizations, MedPAC, and the National
Quality Forum have offered insights and
suggestions on what processes of care reflect
best practices for patients receiving care
in their homes. In addition, agencies who
have been working closely with their QIO
over the past several years have found some
of their own best practice related to some
of these issues.
28.
Will there be individual OASIS-C for the
SN and PT?
OASIS-C items are the responsibility of
both disciplines. The agency is free to
create a discipline specific comprehensive
assessment that incorporates the OASIS-C
data set. Those rules have not changed.
We do not know if CMS plans to provide sample
assessments in the OASIS-C Guidance Manual
as they do in the current. We expect that
private vendors will also provide them.
29.
With the new OASIS-C document, do you think
the plan will be for agencies to still work
a comprehensive assessment into the document?
The OASIS-C document now seems pretty comprehensive
on its own
The OASIS-C items by themselves do not
fulfill the requirement for a comprehensive
assessment. The Medicare Conditions of Participation
require that agencies integrate OASIS items
into their comprehensive assessment form.
30.
When you refer to the state OASIS coordinators
as the "experts", are you talking
agency staff (such as OASIS-certified) or
the State Coordinator responsible at the
state level?
We are referring to the State Coordinator
responsible at the state level.
31.
Will the outcomes measures change with OASIS-C?
Yes, they will change. New measures are
awaiting endorsement of the National Quality
Foundation. We will post their decisions
on our OASIS Complete Resource Page when
they become available.
32. Will
this data set be tied with the patient satisfaction
survey being tested by CMS?
OASIS-C does include process items that
will support the public reporting of evidence
based practices, and it advances the standardization
of many OASIS assessment items with the
Minimum Data Set (MDS) and the CARE instrument
being developed for use across all post-acute
care settings. We are not aware of any imminent
plans to tie the patient satisfaction survey
to this OASIS-C. However, the satisfaction
survey is in line with their goal to support
quality care and a potential Pay for Performance
system.
33.
WOCN teaches such wound measure as: the
length is to be in the 12-6 orientation,
the width at a right angle to the length.
OASIS says the length is the longest measure
in any direction. Why not in line with WOCN
guidelines?
The OASIS-C item M1310 has been revised
from an earlier draft and now states Pressure
Ulcer Length: Longest length “head-to-toe”
which is a 12-6 orientation. CMS indicates
they are in regular consultation with WOCN
and NPUAP for the integument assessment
items. However, historically, CMS has not
been quick to change their forms or their
guidance when wound assessment and care
has changed.
34. I
haven't seen the new OASIS-C tool. Where
can I view the current incarnation?
Click
here for OASIS-C Version 12.2.
