NAHC weighs in on HCFA’s revised guidelines for OASIS

By MATTHEW HAY

HHBR Washington Correspondent

WASHINGTON – The National Association for Home Care (NAHC; Washington) recently weighed in on the Health Care Financing Administration’s (HCFA; Baltimore) revised interpretive guidelines for the Outcome and Assessment Information Set (OASIS) requirements. NAHC reported that while the guidelines have yet to be made public, the association was given the chance to review and comment on the draft.

Given that the OASIS regulations will be modified with the home health prospective payment system and revised conditions of participation in just a few months, NAHC said, it will become "increasingly problematic and costly" to require nurses to perform the initial and comprehensive assessment when the therapy is the primary and first needed service.

According to NAHC, the draft guidelines also contain a statement that "if the initial assessment indicates that the patient is not eligible for Medicare (i.e., the patient is not homebound, has no skilled need, etc.), then there is no indication for the agency to conduct a comprehensive assessment or to collect, encode, or transmit OASIS data to the state."

But NAHC said that statement is confusing because the patient may not be Medicare eligible, but be a private pay patient or covered by Medicaid. In addition, NAHC noted that the OASIS Web site states that even a one-time skilled nursing visit would require an OASIS. "In these cases, however, the patient would not qualify for Medicare because he does not meet the intermittent skilled nursing requirement," noted the association.

In addition to the revised interpretive guidelines, NAHC noted that HCFA intends to revise the sections of the State Operations Manual dealing with separate entity determinations. NAHC also recommended that these determinations be confined to quality and operational considerations rather than fiscal and corporate law considerations, and that surveyors should follow the same procedures for identifying free-standing agencies that are part of a complex organization as they do when surveying hospital-based agencies.

The association added that when determining whether an agency is part of a larger organization, surveyors should base their decisions on the operation of the agency, consumer awareness, and staff awareness regarding this fact.