HCFA delays OASIS requirements

Providers split on continuing collection

After weeks of confusion about its intentions, the Health Care Financing Administration (HCFA) announced April 27 that it has delayed implementation of all collection and reporting requirements for its Outcome and Assessment and Information Set (OASIS).

Mandatory collection of OASIS data by all Medicare-certified home health agencies became effective earlier this year. In its announcement HCFA conceded, however, that for this mandate to be valid, it must first clear several more regulatory hurdles, including the Paperwork Reduction Act.

OASIS participation problematic

In the meantime, HCFA said it is not requiring home health agencies to encode and transmit OASIS data and added that home health agencies that have not met these requirements to date will not be held out of compliance.

The OASIS project has generated considerable controversy, especially among Medicare-certified private duty providers. (See Private Duty Homecare, May 1999, p. 49.) Those who operate private duty and Medicare services in one entity faced performing OASIS assessments on all but a few patients. OASIS would add costs and layers of administration to slim-margined operations radically different from those involving Medicare patients, they argue. The program would be particularly onerous for those with small Medicare caseloads.

OASIS also drew sharp criticism from a variety of health care and policy groups that contend it violates patients’ right to privacy; particularly those whose care is not funded by Medicare.

HCFA initially informed agencies that in the event of a patient’s refusal to complete the OASIS assessment, they should document the patient’s refusal in the chart but continue providing services. Later, it reversed itself and said that under such circumstances, providers could not continue providing services.

This raised still more controversy, as private duty providers, already strapped with added expenses, now faced a loss of business.

Now that HCFA has a least temporarily backed away from the OASIS requirement, the question facing providers is whether they should continue to collect the data.

Chaos in the ranks

"It’s a bad thing what we’re doing. All of these delays will cause HCFA not to have appropriate case-mix information for the [prospective payment system]," says JoAnne Ruden, MPA, RN, president and chief executive officer of the Trenton, NJ-based Visiting Nurse Association of the Delaware Valley. The VNA has both private duty and Medicare-certified services, but they operate out of different entities.

"We’ve already spent the money, time and had all the forms printed out and the staff were just getting used to the flow of it, so to disrupt it and have them go through it again is senseless," she adds.

"I think I would have had a revolution by the nurses on my hands if I’d asked them to continue doing it when they knew they didn’t have to," says Bonnie Whorton, MS, executive director of Moberly, MO-based Home Care of Mid-Missouri. Mid-Missouri operates both its private duty and Medicare-certified operations in one corporation.

In addition to the violation of patients’ privacy rights and added administrative burden, Whorton also sees OASIS as an imposition on sick patients who aren’t interested in an extensive interview when they first receive home care. "I would much rather see it on an exit interview," she says.

Exactly when HCFA will resume OASIS collection requirements remains unclear. However, most observers believe the agency will eliminate the more far-reaching concerns that Congress and others have about the dimensions of OASIS, which means it could be a long wait.

"I think it will be changed enough that it won’t be that much of a hurdle to implement [the second time around]," Whorton predicts.

What is HCFA’s advice?

"Given that the instrument was designed to be useful to home health agencies to assess and improve the care they furnish," the agency stated in its special alert, "they may wish to use the OASIS instrument for their own purposes."

The VNA of the Delaware Valley, for one, intends to. "We’re going to analyze our own data ourselves. There’s good information to be had from this. We still can’t explain why there are regional variations in home care [processes and outcomes]. I’ve been in the field 28 years and I’ve never seen anything to explain it. But OASIS will provide that information," Ruden says.

House, Senate push for home care reform

In the face of growing evidence that home care is at risk, the budget committees of both the House and Senate have approved budget resolutions designed to double the amount of Medicare payments over the coming decade.

The House voted unanimously to approve an amendment sponsored by Reps. Robert Weygand (D-RI), Ernest Fletcher (R-KY), and Paul Ryun (R-KS) to ask Congress to avoid implementation of the 15% reduction under the interim payment system (IPS) and instead opt for a timely implementation of a prospective payment system.

The Senate, meanwhile, passed an amendment sponsored by Sens. Charles Grassley (R-IA) and Russell Feingold (D-WI) that cites the IPS and other Medicare benefit changes as exacerbating "inequalities in payments for home health services between regions, limiting access to those services in many areas and penalizing efficient, low-cost providers."

Congress passes budget blueprints

Rejecting President Clinton’s proposed Medicare funding plan, Congress voted to "lock away" the projected $1.8 trillion surplus funds generated by Medicare and Social Security tax collections until as such time that a major Medicare restructuring bill is passed.

Clinton had tried to push through his plan of putting $700 billion in surplus funds into the Medicare Hospital Insurance Trust Fund over the next 15 years. Instead, the Senate voted 55-44 in favor of the Republicans’ blueprint, which would finance reform proposals such as the ones proposed by (but never formally approved) by the National Bipartisan Commission on the Future of Medicare. The House followed suit with a vote of 221-208 in favor of the GOP plan and rejecting three Democrat-sponsored programs.

Health care providers have come down in favor of the Republican plan which, unlike the president’s, does not include reducing provider payments by $9 billion over the next five years.

Financial management conference scheduled

The National Association for Home Care (NAHC) holds its fifth annual home care financial management conference, "The Year of Transition: Emerging Issues in Financial Management for Home Care," July 7-9 at the Westin Resort in Hilton Head, SC. The conference is designed for agency administrators, chief financial officers, and business managers. It covers a variety of financial management issues, from surviving under the Medicare Interim Payment System to pricing home care services and emerging issues with mergers and acquisitions.

For more information, or to register, contact the NAHC meetings department at (202) 547-5050.