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By MATTHEW HAY
HHBR Washington Correspondent
Not long ago, home health agencies (HHA) faced grueling audits by state surveyors under the Health Care Financing Administration’s (HCFA; Baltimore) Operation Restore Trust. According to veteran healthcare attorney Frank Case of Schmeltzer, Aptaker & Shepherd (Washington), these surveys often turned on highly technical interpretations of the home health conditions of participation (CoPs) and varied dramatically from state to state.
Today, that compliance landscape is being transformed by the new requirements surrounding HCFA’s Outcome and Assessment Information Set (OASIS). Case’s colleague, Denise Bond, warned that while HCFA has instructed state surveyors to take a graduated enforcement approach to OASIS compliance, nobody yet knows what that means.
"I think that means that they are not going to drop bricks on our head like they did in Operation Restore Trust surveys," she said. "But they have not really spelled that out." Bond said the good news is that unlike Operation Restore Trust, HHAs have a regulation that offers a blueprint surveyors will use to measure compliance.
Last November, HCFA published directions to state surveyors in the State Operations Manual explaining what to look for when surveying HHAs to make sure they are complying with the OASIS requirements that have been incorporated into home health CoPs. Bond said the main focus for OASIS centers around data collection and reporting requirements.
The following is a rundown of key areas to which Bond said HHAs should pay close attention:
For comprehensive assessments, HCFA instructed surveyors to take a sample of patients and determine who conducted the initial assessment that should have been completed on or after July 19, 1999. According to Bond, surveyors will want to make sure that the homebound status of the patient was confirmed along with the dates of the referral and initial assessment.
Bond said HCFA also wants surveyors to ensure the timely completion of comprehensive assessments. Before they even go on site, she said, surveyors will determine if assessments are being completed within five days of start of care. "Very often, what we see with this new type of survey is that they look for very simple things that have a time deadline or a documentation requirement," she said. "That is easy to look for and easy to document if it is missing."
In addition, Bond said, HHAs should pay close attention to the type of clinician that completes the start-of-care assessment. She added that surveyors will check on-site visit records to determine who signed the record. "You want to make sure that when that person signs the assessment, they include their title," she said. "The surveyor is not going to be able to tell that Jane Doe is an RN."
According to Bond, HHAs must also ensure that there is adequate data included in the comprehensive assessment. For example, she noted that surveyors have been instructed to assess the agency’s policy on readmitting patients after transfer, such as whether they are put on hold or discharged and how the next assessment date is determined.
Bond also warned that agencies should review patient records to make sure they are collecting appropriate data every second calendar month, within 48 hours of return to service, and at discharge. She said this is another area of which it is easy for surveyors to gauge compliance because it has set time frames.
According to Bond, before surveyors visit an agency, HCFA wants them to review state data reports and make sure that the agency’s encoding is completed within seven days after completing the OASIS data set. Once they are on site, she said, surveyors will choose an assessment completed in the last seven days and perform a home visit to make sure the patient’s overall condition matches the clinical information in the patient’s records. "Here, they want to see if your OASIS data matches your clinical records and, if not, whether the patient’s condition changed in the last seven days," she said.
"I am a little concerned about that because I don’t know how many times they are going to decide that was because there was a change in the last seven days or just assume the assessment was done incorrectly," Bond added.
Bond said surveyors also will try to make sure the other clinical information on the patient’s record does not contradict the OASIS data. "If you have an obvious contradiction, they will conclude your OASIS data is incorrect," she warned.
Surveyors also will be checking to make sure that agencies give existing patients privacy notification regarding OASIS data collection in addition to existing privacy notification requirements, as well as when that information was given to them.