August Compliance Newsletter

OASIS C-2 Questions and Answers

Have you ever come across an unusual patient situation that didn’t seem to ‘fit’ the OASIS? Human beings are so complex and our lives are so varied that it’s no wonder we sometimes find ourselves scratching our heads when trying to select an OASIS response. CMS no longer provides one centralized system to answer and publish quarterly OASIS Questions and Answers, but we have had 20 pages of Q&A’s released from the November 16th/17th Home Health Quality Reporting Training conducted by CMS. Another training was held May 3rd/4th and additional Q&As should be released sometime in August if the timeline is similar to the November event. You can find the November Q&As (released February 2017) on the CMS web page by scrolling to the downloads section at the bottom of the page.

Keep monitoring this page for the release of the May material as there was little public notice of the posting last February. While you’re at this page be sure to download all of the free training materials from the May conference. What kind of questions should you anticipate? One submitted by Fazzi that we hope to see answered is related to M1311. OASIS guidance instructs us to capture a pressure ulcer in Row 2 (A2, B2, C2, D2, E2, F2) if it was present on the OASIS at the most recent Start or Resumption of Care assessment. How should this be interpreted if the ulcer was unstageable at either the last SOC/ROC or at the time of a Transfer, Discharge, or Follow-up OASIS visit? If a pressure ulcer is a Stage 3 at transfer but was unstageable due to slough/eschar at SOC then how could it be determined if it was “at the same stage”? Hopefully, this and other inquiries will be in our hands soon!

Complimentary Executive Update Webinar: Home Health and Hospice Best Practices

Home Health and Hospice CAHPS are key measures of an agency’s success, yet national results have remained unchanged for many years. Wondering how to stand apart from your competitors on Home Health Compare and the soon to be released Hospice Compare to really improve your results?

Join, Gina Mazza, Fazzi’s CAHPS Division leader and a panel of agency leaders to hear real examples and strategies that have worked for them on Wednesday, September 6, 2017 from 1:00 PM – 2:00 PM EDT.  You will receive practical and concrete actions that will help you become a best practice agency.

Register now

New Conditions of Participation (CoPs) Effective Date Officially Delayed

As you may have heard, the final rule delays the July 13, 2017 effective date for the “Medicare and Medicaid Programs: Conditions of Participation for Home Health Agencies” originally published in the Federal Register on January 13, 2017. The rule delays the effective/compliance date for an additional six months until January 13, 2018. Agencies will have until July 13, 2018 to implement one QAPI standard: Performance Improvement Projects.

CMS is planning on releasing the Interpretative Guidelines in December 2017. According to Gina Mazza, Partner, Fazzi Associates, “Agencies should continue to prepare with diligence as most agencies will need the full, additional six months to be in full compliance with new Patient Rights, Care Planning and QAPI standards by January.”

If you have any questions or would like assistance with your plans to comply with the new CoPs, please contact us or call 800.379.0361.

CMS Posting: 2018 HHPPS Proposed Rule – highlights include:

  • Case-mix methodology refinement including a change in the unit of payment from 60-day episodes of care to 30-day periods of care. To be implemented for 30-day periods of care beginning on or after January 1, 2019.
  • Projected reduction of Medicare payments to HHAs in CY 2018 by 0.4 percent or $80 million based on the proposed policies.
  • The adoption for the CY 2020 payment determination of three assessment-based measures calculated from the OASIS to meet the requirements of the IMPACT Act.
  • Refinement of the Home Health Value-Based Purchasing (HHVBP) Model.

Questions? Comments? Contact us today!