Here are a few things home health agencies need to know as PDGM, OASIS D-1 take effect
While most of the nation is catching up on sleep after staying up for midnight champagne toasts or headed to the gym to work off the extra pounds from too many holiday cookies, the home health industry is poised for post-holiday fallout from the Jan. 1 launch of Medicare's complex new payment methodology, the Patient-Driven Groupings Model (PDGM.) It's still too early to report how the new payment model will impact home care providers, but there are signs of early confusion. And PDGM is not the only major change to which home health agencies must adapt as the new year begins. "The first of January always brings big changes to home health -- but this year it's out with the old and in with the new in many different respects," said J'non Griffin, president and owner of Home Health Solutions, a nationwide consulting and outsourcing firm for home care agencies.
"There's the new payment model and a new version of OASIS designed to dovetail with the new payment model and a new iQIES, which is the acronym for the new Quality Improvement and Evaluation System. That's a lot for agencies to deal with right now, and it's all taking place simultaneously these first days of January."
Here are a few survival tips to ease the new year madness for agencies.
An iQIES tip Many agencies reported problems as the new updated system known as iQIES became effective Jan. 1. Agencies had to register by Dec. 23 to use the new system and avoid delays in Medicare payment. But even after registering, some agencies have experienced confusion during the first few days of January about the way rejections are handled under the new system.
In a Facebook discussion group which is sponsored by Home Health Solutions to allow home care providers to discuss PDGM, some agencies reported that in order to avoid confusion, it will be necessary to wait on a final validation report to see what's what with OASIS rejections.
Under the new system, when the agency submits more than one OASIS, a notice of rejection may be received even though only one of the OASIS submissions in the file was actually rejected.
Additionally, each reason for rejection will now be listed separately on the validation report under the new system. Previously, rejections were clustered together.
OASIS D-1 tip
The latest incarnation of OASIS also became effective on Jan. 1. OASIS is the acronym for Medicare's mandatory Outcome and Assessment Information Set, a tool used to assess patients at various times during a home care episode. The new version is designed to work with new PDGM methodology to determine a patient's functional score.
The new OASIS D-1 is less of a major overhaul than last year's transition from OASIS C to OASIS D, but the changes are important -- particularly in light of Medicare's new payment model, J'non said. The new instrument requires the patient's risk for hospitalization and grooming abilities to be assessed for each follow-up OASIS so that this information can be processed into the patient's functional score for PDGM.
Other OASIS D-1 changes allow a total of 23 items on the new version of the assessment instrument to now be marked with an equal sign -- essentially rendering them optional to answer. Here’s an overview of what’s different now:
SOC or ROC Assessments When completing a Start of Care or Resumption of Care OASIS assessment, it is now acceptable to use an equal sign (=) as an answer for: • M1910 Fall risk Assessment
TRN or DC Assessments When completing a Transfer or Discharge OASIS assessment, it is now acceptable to use an equal sign (=) as an answer for: • M2401a Intervention Synopsis: Diabetic Foot Care • M1051 Pneumococcal Vaccine • M1056 Reason Pneumococcal Vaccine not received
Follow-Up Assessments D1 adds these two additional items to all Follow-up Assessments: • M1033 Risk for Hospitalization • M1800 Grooming When completing a Follow-Up OASIS assessment, it is now acceptable to use an equal sign (=) as an answer for: • M1021 Primary Diagnosis • M1023 Other Diagnoses • M1030 Therapies • M1200 Vision • M1242 Frequency of Pain Interfering with Activity • M1311 Current Number of Unhealed Pressure Ulcers at Each Stage • M1322 Current Number of Stage 1 Pressure Injuries • M1324 Stage of Most Problematic Unhealed Pressure Ulcer that is Stageable • M1330 Does this patient have a Stasis Ulcer • M1332 Current Number of Stasis Ulcers that are Observable • M1334 Status of Most Problematic Stasis Ulcer that is Observable • M1340 Does this patient have a Surgical Wound • M1342 Status of the Most Problematic Surgical Wound that is Observable • M1400 Short of Breath • M1610 Urinary Incontinence or Urinary Catheter Presence • M1620 Bowel Incontinence Frequency • M1630 Ostomy for Bowel Elimination • M2030 Management of Injectable Medications • M2200 Therapy Need
When to switch Confused about which version of OASIS to use?
The M0090 Date of Assessment will determine whether OASIS D or OASIS D-1 is used for a patient. If the M0090 Date of Assessment for any OASIS at any timepoint during the episode is Jan. 1, 2020, OASIS D-1 is to be used. Looking for guidance?
There's no revised version of the OASIS-D Guidance Manual for 2020, so you'll need to rely on the previous version until the Centers for Medicare and Medicaid Services (CMS) provides a replacement. PDGM tip Many PDGM questions remain unanswered with the new payment model off to an uncertain start, but one of the top concerns for home care providers is how well their referral sources will work with them to meet new timeframes and diagnosis specificity. One thing that did become readily apparent to home care providers over the weekend, as referrals came in, is that many referral sources are not giving up their old habits in the new year and adapting their referrals to meet new regulations.
"Keep reaching out to referral sources with information about PDGM, " J'non recommends. "Just because the new payment model has been implemented does not mean your work in that regard is over. There's an old marketing adage called The Rule of 7 which says most people need to hear or see a message at least seven times before they act on it. Reach out to all your referral sources this week with a reminder that PDGM just became effective, and it's time now for the changes you've been talking about for months." Stay in the loop This blog post originally appeared as an article in The Absolute Agency, a free monthly e-newsletter from Home Health Solutions. If you'd like to subscribe to the monthly e-newsletter or to our free weekly compliance e-newsletter, sign up here.