What Does CMS Expect from Us?
March 16, 2009
We have posted a link that will bring you directly to the OASIS C dataset. A permanent link is located on your left for future reference or you can click here to get the file without downloading. http://haydelconsultingservices.files.wordpress.com/2009/03/oasis-c-ver12-2.pdf
OASIS-C is here with complete with expectations from CMS on how agencies will use the OASIS-C dataset. Many of the expectations are long term and include the development of a standardized data collection tool that spans all post acute care providers. Other expectations are going to be challenging us as soon as the dataset is effective in January of 2010. A new/revised set of 55 outcomes is already in the works with public reporting expecting to begin in 2011. That means that almost from the onset, your data collection will be affecting your publicly reported outcomes no matter how well or how poorly you are prepared.
CMS also says, relative to OASIS-C that the ‘changes and item deletions are considered to be high priority by CMS and have implications for outcome measurement, risk adjustment of outcome reports, case mix adjustment for prospective payment, data submission procedures and specifications, reporting systems and provider paper work burden”. That is a long list of implications for the dataset and if you read closely, right in the middle of the list is PPS. Although no changes have been proposed yet, it is only logical that in the future, payment will be predicated on the OASIS-C dataset. But, we would also expect no major changes to occur in payment until enough data has been collected with which the statisticians to work. That means, from the beginning, we all have a responsibility to ourselves and each other to report accurate data from the onset so that payment systems will be based upon meaningful data.
CMS also proposes to ‘support or refute anecdotal information, unsubstantiated opinion, or conjecture facilitate consensus building and develop more objective policy decisions’. In other words, they will be looking at the ways in which home health might ‘game’ the system resulting in higher profits at a cost to patients.
The number of questions that are required for data collection at each point in time do not increase with the exception of the transfer assessment. The current assessment has 11 items collected and OASIS-C asks for 19. The remainder of assessment items are increased by only one or two questions.
The most alarming information that CMS published relative to the new dataset is the amount of time it will take to train staff to accurately assess patients using the new dataset. CMS expects it will take about four hours to train a clinician. While this is certainly a good start, I do not envision that amount of training to be adequate. However, until a revised Chapter 8 is published, we are unable to determine with any certainty how much training we do think is advisable. Additionally, ‘training’, as in learning the dataset in an inservice setting, is not going to fully prepare clinicians to work within the dataset. Our challenge, and yours, is to incorporate training throughout the rest of the year in ways that do not cost the agency, compromise patient care and result in highly qualified assessors next January.
We will surely have more to follow on the OASIS-C dataset as we have time to fully digest the information. Your comments are always welcome below and questions can be emailed to haydelconsultingservices@bellsouth.net
OASIS C is Here!
March 13, 2009
The long awaited OASIS-C is here. You can download the dataset and supporting documentation here http://www.cms.hhs.gov/PaperworkReductionActof1995/PRAL/itemdetail.asp?filterType=none&filterByDID=-99&sortByDID=2&sortOrder=descending&itemID=CMS1217682&intNumPerPage=10.
In the near future, we will be preparing both online and presenter based training for OASIS C. Right, wrong or indifferent, this is now our dataset and the challenge is to make it work for us and our patients. You comments are always welcome below and questions can be addressed to haydelconsulting@bellsouth.net.
On the Eve of OASIS-C
March 12, 2009
Tomorrow, we will be getting our first look at OASIS-C . If everything goes according to schedule, we will be using this dataset beginning January of next year. The preliminary set shows significant changes and we will likely be devoting a lot of time throughout the end of the year to learning the dataset.
Right, wrong or indifferent, the published dataset will become the standard for home health. Our time for suggesting changes has come and gone. The only thing left to do now is to learn the changes and incorporate them into our daily routines.
Before we dive headfirst into a new data set, I want to take one last opportunity to challenge you to make the current dataset as useful to your patients as possible. Getting paid is good. Superior outcomes are great. Easy, relaxed surveys are a joy. But using the data to improve patient care outranks all those reasons to get your data right!
In reviewing clinical records at a variety of agencies in the recent past, these are some of things that I see across the board that warrant extra attention:
Diagnosis Coding: The assignment of primary diagnoses and significant co-morbidities influences more than payment. Any clinician assuming care for the patient after the initial care plan will read the diagnoses coding and direct time and energy to those diagnoses. Incorrect coding, including the omission of any pertinent codes, can compromise patient care.
Vision: Whether or not you receive points in the clinical domain for vision, it is amazing to me how many patients have severely impaired vision that is not addressed in visit notes. One of my clients has an extensive low vision program. The supply all their patients with a black hand towel to lay down while taking meds. That way if a pill drops it is easy to see. How hard is that?
Pain: I read charts all the time that have pain noted throughout the episode. It seems nothing short of tragic to have a patient experiencing moderate pain on a daily basis with no phone calls to the MD or changes in care plan noted.
Wounds: As nurses, we have gotten very good at performing wound care exactly as ordered by the physician. However, the most expensive products in the world will not facilitate healing if the patient isn’t getting enough high quality protein, vitamin C and Zinc. We are missing an opportunity to make a big difference in our patients’ lives by overlooking nutritional needs of wound care patients.
Functional Limitations: We’ve gotten pretty good at assessing if the patient can safely ambulate, transfer, etc. And we are pretty good about ordering physical therapy and home health aide services for patients requiring help. But what about OT? How many patients could benefit from modifications in their living environment under the guidance of a qualified Occupational Therapist?
Before we move onto a new dataset, let’s make a point to make the current dataset as useful as possible to our patients. Because there are no changes in the payment system at this time, we can expect these questions to remain as part of the new dataset.
Be sure to check out our online learning opportunity, ‘Making PPS Work for You’ to your left on this blog. As always, we welcome your comments below in the comments section or by email to haydelconsulting@bellsouth.net.
Update on OASIS-C Final Version
March 5, 2009
Many of you have been referred to our blog searching for information on OASIS-C. Most of you have undoubtedly heard that the updated version was published yesterday. Unfortunately, that published version was incorrect according to CMS and the updated version will be published once more on March 13, 2009. Many thanks to Maria Tsigas of Home Care Outcomes for keeping us up to speed. We promise we will post our updated comments once the final document is posted and we have had time to do a thorough review.
OASIS MO620
March 3, 2009
MO620, is one of the most frequently misunderstood OASIS questions in our experience. It asks for the frequency of behavior problems and then goes on to give the examples of wandering episodes, self abuse, verbal disruption, physical aggression, etc.).
Reading further in Chapter 8 of the OASIS Manual in the definition section, it states:
MO620 identifies frequency of behavior problems which may reflect an alteration in a patient’s cognitive or neuro/emotional status. “Behavioral problems” are not limited to only those identified in MO610. For example, “wandering” is included as an additional behavioral problem. Any behavior of concern for the patient’s safety or social environment can be regarded as a problem behavior.
Therefore, if MO610 has any response other than ‘none of the above’, MO620 would be expected to reflect the frequency of the problem behavior. It would be an inconsistency in data to any problem noted in MO610 and have any response less than ‘several times each month’ noted in MO620.
Keep in mind that MO620 can also refer to problems that are not noted elsewhere in the OASIS assessment. Memory impairment may be such that it does not require 24 hour supervision but may be of concern in the patient’s social environment.
The key to consistently answering MO620 correctly is to understand that the question refers to all problem behaviors, not just the four examples stated.
As always we are open to comments and questions in the comments section below or by email at haydelconsulting@bellsouth.net. Making PPS Work for You, an online educational offering about OASIS is now available from Haydel Consulting Services LLC.
