HCFA surveyors target HHAs on OASIS compliance
HCFA surveyors target HHAs on OASIS compliance
Not long ago, home health agencies (HHAs) faced grueling audits by state surveyors under the Health Care Financing Administration’s (HCFA) Operation Restore Trust initiative. According to veteran health care attorney Frank Case of the Washington, DC-based firm Schmeltzer, Aptaker & Shepherd, those audits often turned on highly technical interpretations of the home health conditions of participation, 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, warns that while HCFA has instructed state surveyors to take a graduated enforcement approach to OASIS compliance, yet nobody knows what that will mean in practice.
"I think that means that they are not going to drop bricks on our head like they did in Operation Restore Trust surveys," she asserts. "But they have not really spelled that out." Bond says the good news is that HHAs now have a regulation that offers a blueprint surveyors will use to measure compliance under OASIS.
Last November, HCFA published instructions to state surveyors in the State Operations Manual to make sure HHAs are complying with the OASIS requirements that have been incorporated into home health conditions of payment. Bond says the main focuses for OASIS are data collection and reporting requirements.
Here is a rundown of key areas Bond says HHAs should pay close attention to:
For comprehensive assessments, HCFA instructed surveyors to examine a sample of patients to determine who conducted any initial patient assessment 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 says HCFA also wants surveyors to ensure the timely completion of comprehensive assessments. Before they even go on site, she says, surveyors will determine if assessments are being completed within five days of the 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 warns. "That is easy to look for and easy to document if it is missing."
In addition, Bond says HHAs should pay close attention to the type of clinician that completes the start of care assessment. She adds that surveyors will check on-site visit records to determine who signed that record. "You want to make sure that when that person signs the assessment they include their title," she cautions. "The surveyor is not going to be able to tell that Jane Doe is an RN."
According to Bond, HHAs must also ensure that adequate data are included in the comprehensive assessment. For example, she notes 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 warns 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 says this is another area easy for surveyors to gauge compliance because there are 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 says, 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 to clinical information in the patient’s records. "Here they want to see if your OASIS data match the clinical records and, if not, whether the patient’s condition changed in the last seven days," she asserts.
Bond says surveyors also will try to make sure the other clinical information in the patient’s record does not contradict the OASIS data. "If you have an obvious contradiction, they will conclude your OASIS data are incorrect," she warns.
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.
Not only that, Bond says, HCFA wants surveyors to question patients to make sure patient confidentiality is maintained. She says that will include an interview with the HHA system administrator to make sure that person knows how to add, edit, and modify the encoded data. They will also check to see whether there is a procedure in place to assign passwords, she notes.
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