The expansion of OASIS is yet another hurdle home health agencies will have to face in the future.
It could be a massive undertaking, and one that still comes with some uncertainty in regards to the financial burden for agencies.
“Right now, some agencies love that they are only required to record OASIS data on, for example, private insurance, because it cuts down on the work they have to do,” Cindy Krafft, co-owner and co-founder of the consulting firm Kornetti & Krafft Health Care Solutions, told Home Health Care News. “But agencies can’t make insurance companies pay any more for that first visit, so there’s some concern about OASIS expansion to all patients, because where is that payment going to come from?”
As it stands now, certain private insurance companies require home health providers to report OASIS data on patients.
For providers, payment and outcomes are directly impacted by OASIS data collection. It’s important for agencies that the data accurately reflects the status of the patient.
After delays that were tied to the COVID-19 pandemic, OASIS-E is being implemented in January in order to line up with the start of the nationwide expansion of the Home Health Value-Based Purchasing (HHVBP) Model.
While agencies have been preparing for OASIS-E for nearly a year now, they will also have to prepare for other changes related to OASIS after the final rule was published.
“CMS adjusted the 2023 impact of the OASIS on case-mix weights,” John Rabbia, the director of SimiTree, said in a recent webinar. “In 2022, agencies had the possibility of accumulating 112 points that would impact your case-mix weight. In 2023, that’s been reduced to 109.”
Payments for home visits that include dressing, bathing and transferring, for example, could be affected, he said.
The other major OASIS news in the final rule was the suspension of OASIS data collection.
“For better or for worse, we’re going to have to start collecting OASIS for all payers, not just Medicare,” Rabbia said. “We have a phasing period starting Jan. 1, 2025, and then financial penalties will be imposed for not collecting that data beginning in 2027. We’re going to want to start thinking about that now and how it’s going to impact your agency.”
Because so much is unknown in how the changes will affect agencies’ bottom line, it’s important for providers to make sure they are optimizing their revenue.
“Anytime you see a reduction in payment or a net neutral, you always want to ask yourself if you are optimizing the revenue you have,” Rabbia said. “Whether that be from a LUPA management standpoint of making sure that you’re minimizing the number of LUPAs you have, or optimizing what your case-mix is. We always recommend doing a sample review of OASIS to see that you’re having that accurate coding completed and that your OASIS are being answered accurately.”
It’s also crucial that home health providers participate in upcoming comment periods for the OASIS expansion, Krafft said.
“I think people were like, ‘Yay, they delayed it.’ But CMS didn’t say they weren’t going to do it,” Krafft said. “There needs to be more discussions and participation in comment periods down the road with specific concerns, particularly around how this is going to be paid. As we move forward, we have to have an open dialogue with CMS because there may be some concerns about the expansion.”
OASIS-E around the corner
Another major hurdle agencies are grappling with is OASIS-E itself.
However, Krafft doesn’t see the implementation of OASIS-E as the doom-and-gloom change many others do.
“In reality, the entire thing is not new,” Krafft said. “75% of OASIS-E is OASIS-D1. What we’re seeing in the last few weeks is what we typically see in this industry, which is, ‘Oh my gosh, it’s almost January, and I need to do something.’ I understand that because why train in June what they can’t use until January. Our mantra has been that if you can get the 75% done and down like a well-oiled machine, in this window you can just focus on the 27 questions that are new.”
Agencies should be sitting down with their clinicians, running through the OASIS-E manuals. And expectations should not be to memorize all of the new questions. They’re not meant to be memorized, Krafft said.
“In our industry, instructions and directions are what reviewers look at, educators look at, that’s what a select few look at,” she said. “My argument is that they wrote the directions for the people collecting the data so they know what to do in those situations. What I’ve really tried to drive home is that some of these items are quite complicated, there’s a reason they give you instructions.”
That being said, there will still surely be an operational burden.
“We are estimating — and CMS is estimating — that it’s going to be about a four-hour visit for an OASIS-E start of care,” Rabbia said. “Based on how your agency measures productivity, whether it’s by points or by visits, we can plan on about a four-hour visit, and that’s after the learning curve.”
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