OASIS mandate looms ever larger

HCFA holds to tight time line in pursuit of PPS

Among the many Balanced Budget Act of 1997's mandates, the Outcomes Assessment Information Data Set (OASIS) reporting requirement may be one that most significantly affects their operations.

The Health Care Financing Administration (HCFA) expects to publish the final rule requiring all Medicare-certified home health agencies to submit OASIS clinical data to state and national databases this July. Agencies may be required to collect data using OASIS tools as soon as 30 days after final rule publication. Full implementation, including electronic data transmission, will probably begin just a short six months later in January 1999.

Helene Fredeking, director of HCFA's Center for Medicaid and State Operations, Division of Outcomes and Improvement in Baltimore, out-lined HCFA's plans regarding this crucial out-comes reporting requirement, a cornerstone of the agency's planned Oct. 1, 1999, prospective payment system (PPS) implementation. The aggressive time line will only be successful with the collaboration of HCFA, state agencies, industry representatives, and home health agencies, she says.

Under the revised system, agencies will continue submitting payment information to fiscal intermediaries (FI) as they are now doing. At a date to be determined later, possibly as soon as 30 days after the final rule's expected July publication, agencies will begin using the OASIS assessment tool on all Medicare patients. Then, most likely on Jan. 1, 1999, they must also transmit OASIS data to their designated state agency, usually the Medicare survey entity. The state agency will audit and advise agencies of errors before transmitting the data to HCFA. HCFA will then match FI and state agency-submitted OASIS data, eventually using it to prospectively pay home care agencies.

Although HCFA is currently developing provider data specifications, they will be similar to those now used by nursing home providers, says Fredeking. These requirements should be available by the time HCFA publishes the final regulations, she says.

HCFA will provide a bare-boned data-entry package lacking care planning and other more comprehensive capabilities. Agencies may either use this standard-issue system or a program of their choosing. HCFA will offer home health agencies the vendor selection and system development training module it developed for nursing home providers, she adds.

Although still under development, home health agency training vehicles will probably parallel those HCFA offered during the nursing home OASIS implementation, says Fredeking. Examples include a training manual and communiques available on HCFA's Internet site (http://www.hcfa.gov/), vendor preparation, a standardized education package for state agencies, and a nationwide satellite training conference. HCFA is also considering a CD-ROM education module, she indicated.

Time lines are tight

While industry representatives support PPS implementation and recognize the importance of OASIS data in developing crucial case-mix indices, they argue HCFA's short time line will impose yet another operational hurdle when providers are struggling with the interim payment system aftermath. NAHC, on behalf of member organizations, has proposed that HCFA not require agencies to use the OASIS assessment tool sooner than 90 days following final rule publication, says Margaret Hoffman, associate director of regulatory affairs.

"There is no question the time lines are tight, but providers are not satisfied with [Interim payment system]," says Fredeking. She argues that agencies should begin using OASIS as soon as possible so that "they can get used to doing it rather than learning everything at one time. [And we believe] the data will be better with a phased implementation."

NAHC is surveying members to determine how many are currently using OASIS. Fredeking estimates about 200 providers participate in one of several OASIS demonstration projects. There are more than 9,000 Medicare-certified home health agencies.

The OASIS implementation will require additional agency resources, from field staff training and - at least initially - slower visit times for assessment tool administration, to hardware upgrades. In recognition of these obligations, Mary St. Pierre, director of regulatory affairs, announced at the NAHC policy conference in Washington, DC, in March that NAHC is pursuing special OASIS implementation payments from HCFA. Fredeking says she has no knowledge of HCFA providing additional funding, but she is not the decision-maker on that issue.

With rapid implementation and many operational requirements, communication between HCFA, home health agencies, and state agencies will be critical. HCFA will work with each state's designated OASIS office, NAHC, and the Center for Health Policy and Research in Denver, which is coordinating many demonstration projects, to develop a communication plan, Fredeking says. In addition to designating a state OASIS coordinator responsible for answering questions and providing training to providers, HCFA will develop a home health Internet site to communicate updates and other important information.

Fredeking encourages providers to view HCFA's nursing home site at http://www.hcfa.gov/medicare/hsqb/mds20 for a taste of what to expect. The home care site, probably on-line in May, will be similar. Home health agencies should routinely check the Web site and remain up-to-date on HCFA guidelines so that "they make necessary adjustments in their operations and are not unprepared to fulfill a requirement at the last minute," she adds.