Open Letter to CMS

Centers for Medicaid and Medicare

Washington DC

Reference: OASIS-C Dataset

To Whom it may concern:

This letter is to inform you that my clients have opted out of the OASIS-C dataset based upon my recommendations. We will continue to use the OASIS B-1 dataset for the foreseeable future. While I recognize the problems with the current dataset, it is my opinion, fueled by the enthusiastic resistance of my clients, that the new dataset is even more confusing.

In order to teach the dataset, I have had to teach my clients how to lie. This is not a pleasant task for a consultant who respects honesty and integrity. And yet, the dataset repeatedly tell us that certain wounds will never heal but when responding to questions about healed wounds, we are to pretend that they are healed and lie.

Furthermore, we are not certain we can comply with physician notification requirements. The definitions of communication and physician designee should be clear but in the magical way of CMS, no one really knows what you are talking about. How much time do you expect my clients to spend collecting data that will be useless in another year because the questions are answered inconsistently?

One thing that I am really grateful for in the new dataset is that CMS does not mandate best practices as is stated repeatedly. All this teaching and training and my clients are still free to use mediocre practices. That’s very considerate of CMS. But, did it ever occur to you that no one wants to admit to using bad practices and therefore the data will again be rendered useless?

I am so relieved that we are spending an enormous amount of time investigating the patient’s ability to get to the bathroom, remove appropriate clothing, and manage the hygienic tasks associated with healthy skin and get back out of the bathroom safely. I noticed you added yet another question about toileting and I personally wonder if this is enough. Toileting is important. And yet, equally as important to a patient’s ability to participate in a plan of care is literacy and financial factors. Why chart that a patient is unable to get off the toilet and make a big deal about it if they can’t afford a toilet seat extension that makes it possible? And yet the dataset does not take into consideration the fact that most of my clients are rural and have a large number of functionally illiterate and impoverished patients. They are going to look horrible on outcomes reports!

Of course, there are many, many reasons why we choose not to adopt the OASIS-C dataset as recommended by CMS. Without going into all of them, consider this. I have a four inch binder on my desk with over 1000 pages of instructions on how to answer a 20 page dataset. Not only have I read every word but so have most of my clients. And we still can’t agree on what is said!

Should you decide to make any changes in the dataset or have it re-written by a person who speaks English as their primary language, please let us know at once and we will re-consider participating in OASIS-C activities.

With Warm Personal Regards,

Julianne Haydel

Consultant Extraordinaire

Note: For those readers who will choose to use the OASIS-C dataset, we are continuing education about the dataset the way it was meant to be taught; not the way we think it should be taught. Call us at 225-216-1241 for more information or check back regularly for new dates to be scheduled in December.