HCFA memo clarifies OASIS requirements
HCFA memo clarifies OASIS requirements
Change of ownership procedures outlined
A May 24 memorandum from the Health Care Financing Administration (HCFA) to the organization’s region offices and state survey agencies redefined the group’s requirements for reporting Outcome and Assessment Information Set (OASIS) data when there has been a change in home health care agency ownership (CHOW). This information is courtesy of the National Association for Home Care in Washington, DC.
The instructions categorize CHOW situations as follows:
Change of Ownership/Mergers
In the case of a merger, one agency (Agency A) terminates its provider agreement and surrenders its provider number, discharging all patients. The second agency (Agency B) retains its existing provider agreement and number, admitting all patients it receives from Agency A.
In this case, Agency A should provide the OASIS discharge comprehensive assessment for each discharged patient prior to, or at, the effective date of the merger.
Agency B, the surviving agency, should provide a start of care (SOC) comprehensive assessment for all persons it admits at the next skilled visit after the official merger date.
Change of Ownership with Assignment
When there is a change in ownership and the new owner accepts assignment of the existing provider agreement, the new owner is subject to all the terms and conditions under which the existing agreement was issued. In these cases, the provider number remains the same and the new owner is responsible for continuing to complete updates to the comprehensive assessment at the next scheduled time points.
Change of Ownership Without Assignment
When there is a change of ownership and the new owner rejects assignment of the provider agreement, the current provider agreement and number are terminated. The new owner must complete the application process for a new agency and comply with all federal requirements, including OASIS. In these cases the agency that is terminating should provide an OASIS discharge comprehensive assessment for each patient prior to the effective date of the termination. The new agency must provide a new SOC comprehensive assessment at the first skilled visit once it becomes Medicare approved. Also in the memorandum are additional instructions for voluntary and involuntary agency terminations.
Voluntary Termination
When an agency voluntarily terminates its provider agreement, the agency should file a written notice of intention to terminate to the state agency, who in turn notifies the region office. HCFA recommends that these agencies provide a discharge comprehensive assessment for each patient prior to the termination date.
Involuntary Termination
In cases where the HCFA region office terminates an agency provider agreement, HCFA will work with the agency on a case-by-case basis to provide for the safe transfer of patients to a new agency. The agency to whom the patients are transferred should provide a new SOC comprehensive assessment.
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