Have you submitted your OASIS data? All of it? Have you looked at your validation reports in great detail to ensure that there was not one fatal error that may have been overlooked?
What about your HHCAHPS data? Have you been diligent about submitting it? If your agency had less than 60 patients from March 31 through April 1, have you submitted an exemption request on the HHCAHPS website?
If you are not 100 percent sure about these answers, it might be a really good time to find out and ensure that you have met your data submission requirements. You will be penalized if your OASIS and/or HHCAHPS data isn’t submitted.
The penalty sounds modest enough – 2 percent. But unless you are really good at doing business or really bad at taking care of patients, that 2 percent could be anywhere from 20 to 50 percent of your margin. If you are really good at taking care of patients and mediocre in the business area, this modest 2% could devastate you.
The Medicare Guidance, which can be found here, reads:
In calendar year 2007 and each subsequent year, if a home health agency does not submit required quality data, their payment rates for the year are reduced by 2 percentage points.
Notice the reference to the year 2007? The actual reg has been in effect even longer than that and only a couple of agencies here and there were penalized. The Office of the Inspector General took notice of that earlier in the year and penalties are on the way. The Medicare Administrative Contractors (MAC’s – formerly FI’s also known as Palmetto, Pinnacle, etc.) have received these instructions straight from CMS:
Each fall, Medicare contractors with home health workloads will receive a technical direction letter (TDL) which provides a list of HHAs that have not submitted the required OASIS and/or HHCAHPS data during the established timeframes. These Medicare contractors shall review their paid claims history for claims which have:
- a provider on the (naughty) list
- Dates of service from July of the previous year
- Beneficiaries over 18
Here’s the part that is really good:
If the contractor finds any such claims, the contractor shall notify the HHAs that they have been identified as not being in compliance with the requirement of submitting quality data and are scheduled to have Medicare payments to their agency reduced by 2%.
I have yet to see where a threshold for compliance has been set. It does not say if the majority of data was submitted or if 90 percent of the data was received.
It also doesn’t say how they are going to identify the providers. Will they look for gaps longer than 3o days between submissions?
My experience is not reassuring. Agencies have received deficiency notices for late submissions but there have a number of times over the past few years when no data was submitted. Nothing has been received when no data was submitted.
In one agency, a young lady had indeed submitted the data and placed the validation reports in a binder just as she was told. Her instructions should have included reading the reports. Every single assessment had been rejected for a period of six months.
Several times in several different agencies, the person responsible for data submission left employment. When they did, nobody picked up the relatively insignificant task of transmitting data.
If I were an administrator or a Director, you can prevent disaster by:
- Requiring OASIS data to be submitted every two weeks. It is not unheard of that uploading data is difficult and time consuming
- Require written confirmation that the task was done.
- If you use outlook, put a recurring reminder with an email that goes out two days before data is to be uploaded. That way, if you forget about all this a year from now and the person uploading the data leaves, you will get a bounced email
- Actually look at validation reports and ensure they are being addressed.
- A system of verifying with your HHCAHPS vendor that submission of data has occurred according to your contract.
If you are a field nurse or someone else who doesn’t deal with OASIS transmission, don’t hesitate to bring a copy of this to the people who do to remind them of the importance of it. If they are offended, walk it off as my son’s coaches used to say. I can pretty much guarantee that you will not get a raise next year if your agency takes a 2 percent hit.