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What Does CMS Expect from Us?

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.

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

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