Home care industry pushes for further changes in OASIS

By MATTHEW HAY

HHBR Washington Correspondent

WASHINGTON – The Health Care Financing Administration (HCFA; Baltimore) is reportedly working on further changes in its Outcome and Assessment Information Set (OASIS), but an agency spokesman told HHBR at presstime that no immediate changes are expected.

Last week, the agency announced that the effective date for home health agencies to begin transmitting OASIS data will be later than the April 26 date currently specified in the OASIS reporting regulation. The new "go-live" date will be 30 days after HCFA publishes "a system of records" in the Federal Register, which is expected to take place later this month.

Many observers believe HCFA will be forced to make further concessions, including modification of the collection process to ensure that patient-specific, identifiable information is not included. In the meantime, however, home health agencies must comply with all of the requirements of the OASIS program. In its communication last week, HCFA reiterated that agencies are expected to conduct comprehensive assessments, including the OASIS data, as currently required under the new conditions of participation.

The delay in the effective date did little to ease the concerns of the home care industry. "There is no real relief here at all," said Gene Tischer, executive director of Associated Home Health Industries of Florida (AHHIF). Tischer argued that instead of making the OASIS requirement "agency-wide," HCFA should make it "patient-wide" by eliminating non-Medicare patient populations, such as private-pay and commercial insurance.

The National Association for Home Care’s (NAHC; Washington) Bill Dombi takes a similar view. According to Dombi, the only data that has immediate value to HCFA is Medicare patient information for purposes of constructing the prospective payment system (PPS). "HCFA, itself, intended to have this data collected for a significant period of time before they intended to make any use of it," Dombi noted. Only after HCFA has OASIS up and running should it collect this data on non-Medicare patients, argued Dombi. "At that point we think it would be appropriate to collect it on all patients."

NAHC also continues to argue that home health agencies should not be forced to bear the expense of collecting this data. "That puts home care in a very difficult position and sets a very bad precedent for any other administrative changes directed by HCFA," Dombi asserted. "Nobody else in health care is facing this kind of requirement."

In addition to excluding non-Medicare patients and securing adequate reimbursement, NAHC recently submitted the following recommendations in response to HCFA’s regulation on OASIS: provide a minimum of 72 hours or more for HHAs to complete the discharge or to transfer the OASIS data after the agency has knowledge of its occurrence for a given patient; modify the requirements to encode and finalize data to 14 working days after completing OASIS data; clarify the language to require transmission of OASIS data, at least monthly, only for patients for whom data was collected in the previous month; make technical corrections to the HAVEN software; incorporate policy language in the final rule that will enable data to be transmitted from branch office sites using the agency’s assigned log on identification and password; provide immunity and/or indemnification to HHAs that transmit confidential, patient-identifiable information by electronic means; and withhold any dissemination of OASIS-related data until the new privacy regulations are released.