Home Health Physical Therapy Archives - Page 3 of 4

Mar 5

Update on OASIS-C Final Version

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.

Mar 1

We Need Your Help!

As we plan future projects, it occurs to us to ask home health agencies to give us their input on what kind of education fits best into their routines. Please take just a minute and answer the following, single question poll. Results are available for all to see.

Thanks.

Dec 23

1 Comment

Santa Baby

Dear Santa:

I hope you and the elves are doing well. I saw a few elves at dinner the other night. Frankly, they were tanked and I hope that doesn’t impede progress in the North Pole.

But, in case it does, I am humbly preparing a list that doesn’t require a bunch of drunken elves to deliver; not to mention an antiquated sleigh that apparently is not equipped with GPS. I refer to the time you brought the kitten I wanted to the neighbors and I got stuck with the Easy Bake Oven with a stupid light bulb instead of gas to provide heat.

But now, fat man in red, I am giving you the opportunity to make up for the lame Easy Bake Oven by bringing me a new set of coding guidelines for home health. I want a coding system with random assignment of codes. I want a coding procedure that doesn’t have manifestation codes, V-Codes, E-Codes or anything else of the sort. If you ever read the list of E-Codes, you would know how depressing it gets to read all the bad things that can happen to the human body. Such knowledge does not impart the Christmas Spirit you claimed to promote before the Easy Bake Oven fiasco.

And of course, the kitten you gave the neighbors got run over in front of my driveway. Did you forget that? Would you like to make it up?

How about a Home Health Assessment that isn’t so complicated it requires letters and numbers just to get the version straight? The term OASIS conjures up visions of palm trees and beaches and relaxation. It is a sick, sick joke perpetrated on nurses and is about as funny as the kitten being run over in my drive way.

My therapist seems to think I am making progress about the events surrounding your gift of a chemistry set to my brother. The scars are fading and I am once again able to smell sulphur without remembering all my Barbies perishing in the great fire that also took out my Barbie mansion, and the GI Joe tank Ken used for transportation. I still have nightmares about little melted pumps littering the floor of the play room.

I know it would help me with my resentment towards you if only you were able to bring to CMS some common sense about medical billing. Here’s how it should work. You take care of a patient. You see how much it costs to do so. You tack a modest amount on for a profit. You submit the claim. Medicare pays.

How hard is that? It should be easier than watching a little girl spend an entire weekend burying Barbie Dolls in her back yard cemetery that spans over an acre.

And if none of that is possible, then please just bless all of those I know with love and good fortune for the New Year. We will take care of the rest.

julianne

Dec 18

Vendor or Provider?

One of home care’s greatest advocates, Elizabeth Hogue, Esq. has been generous enough to share her thoughts with our readers regarding the treatment of post-acute care providers as providers. Many larger institutions guard information regarding their patients like the queen’s jewels. The worst case scenario is poor coordination of care resulting in suboptimal care at home following a hospitalization. Elizabeth’s legal expertise and analysis of the differences between Vendors and Post-Acute Providers can help you understand your rights as a provider in order for you to obtain the information you need to care for patients.

Post-Acute Providers Are Not Vendors

Elizabeth E. Hogue, Esq.

Office: 877-871-4062

Fax: 877-871-9739

E-Mail: ElizabethHogue@ElizabethHogue.net

Some hospitals and skilled nursing facilities (SNF’s) refer to post-acute providers as “vendors” and require them to follow the policies and procedures related to “vendors.” These may include, for example, a requirement for representatives of post-acute providers to sign in when they arrive at hospitals and SNF’s to coordinate services in hospitals’ Purchasing Departments.

On the contrary, post-acute providers; such as home health agencies, home medical equipment (HME) companies, hospices and private duty home care agencies; are not “vendors” and should not be treated like “vendors.” They are, instead, fellow providers. Vendors are manufacturers and distributors of supplies and equipment that are utilized by hospitals and SNF’s on the premises of institutions. Post-acute providers rarely sell equipment and supplies that are used by facilities on the premises. In fact, the users of post-acute providers are patients, not hospitals and SNF’s.

When hospitals and SNF’s lump post-acute providers in with equipment and supply vendors they are, at the least, being disrespectful of these types of providers. Such treatment may be demeaning to post-acute providers.

Some hospitals are asking post-acute providers who are categorized as vendors to pay fees to hospitals in order to appear on a vendor list. Such payments are likely to constitute illegal kickbacks in exchange for referrals and cannot be required.

In addition, restrictions that hospitals and SNF’s may appropriately put on the activities of vendors while on the premises are inapplicable to post-acute providers. Vendors may, for example, be prohibited from going to other areas of institutions besides purchasing departments unless they are accompanied by staff of facilities.

No such restrictions should be applied to post-acute providers. In fact, it is inappropriate to restrict the activities of post-acute providers who:

– Have received referrals of patients; or

– Cared for patients immediately prior to their admission to institutions

Under these circumstances, post acute providers should be permitted access to patients, their families, and information about them as part of the discharge planning process.

It is important to note that referrals for post-acute services do not have to come from physicians. They may come from patients, their families, physicians, case managers/discharge planners, or other sources. Referrals may also be received by post-acute providers, either verbally or in writing. When post-acute providers are acting on verbal referrals, they should, however, document the name of the person who made the referral and the date and time at which it was received.

Of course, patients have the right to freedom of choice of providers. This right to freedom of choice of providers includes the right to self-refer to any type of post-acute provider. There are a number of sources of this right, as follows:

1) All patients have a common law right, based upon court decisions, to control the care provided to them, including who renders it. Thus, when patients, regardless of payor source or type of care, voluntarily express preferences for providers, their choices must be honored.

2) Federal statutes of the Medicare and Medicaid programs guarantee Medicare beneficiaries and Medicaid recipients the right to freedom of choice of providers. (Medicaid recipients may have waived this right if they participate in a waiver program.) Consequently, when Medicare patients and non-waiver Medicaid patients voluntarily express a preference for a home health agency, these choices must be honored.

3) The Balanced Budget Act of 1997 (BBA) requires hospitals to develop a list of home health agencies that are:

a) Medicare certified;

b) Provide services in the geographic areas where patients reside, and;

c) Ask to be on the list.

In addition, if a hospital places the name of an agency on the list in which it has discloseable financial interests, the relationship between the hospital and the agency must be disclosed on the list.

This list must be presented to all patients who may benefit from home health services, regardless of payor source, so that they can choose the home health agency that they wish to provide services to them.

4) Hospital Conditions of Participation (COP’s) that became effective on October 1, 2004, include the basic requirements of the BBA described above.

5) Court decisions, such as the opinion in Assured Home Health, Inc. v. Providence Health System, also support patients’ right to freedom of choice of providers. In this case, Assured claimed that the hospitals in the System regularly violated patients’ right to freedom of choice and “steered” patients to agencies owned by the System. This case was settled when the System agreed to institute additional safeguards to protect patients’ rights, including monitoring of the hospital’s practices by outside third parties.

A patient who received services from a post-acute provider immediately prior to admission to an institutional setting may, of course, choose to receive services from a different provider upon discharge. If a patient does not choose another provider, his or her care should be continued by the same provider with which the patient is likely to have a continuing provider-patient relationship.

Likewise, patients who are referred to post-acute providers may, of course, choose different providers any time they wish to do so.

Patients greatly value the services that post-acute providers offer. Hospitals and SNF’s, therefore, should not treat them like “vendors.”

Dec 7

OASIS-C Summary of Changes

We have completed an initial review of the proposed OASIS-C changes compared to the current OASIS B-1 data set and summarized our findings below. As consultants, we have a opinions and a burning desire to share – and we do exactly that in the coming weeks. However, this post is limited to a simple outline of the changes as we see them. Because it is only an initial review, it is possible that we have minor omissions in our review and welcome any corrections. Furthermore, we will be preparing comments for CMS and as such, your comments and opinions are not only welcome but solicited in the coming weeks.

Clinical Records and Diagnosis

There are two new questions in the Clinical Record items (the section that deals with reasons for assessments, person completing assessment, etc.) These questions refer to the referral date for Start of care/resumption of care dates and the actual date that care began or was started. Currently, CMS has a 48 hour time frame between referral and admission and a 24 hour time frame for resumptions of care. Some states such as Louisiana mandate 24 hours between referral and admission.

The data collected regarding prior diagnoses has changed in its format. Additionally, the OASIS-C data set is asking for each inpatient procedure and associated ICD-9 code to be included.

The diagnosis coding for the episode remains in the same format with four columns including severity. As with the data set released for use last January, CMS does not ask for onset or exacerbation dates. This is not a CMS requirement but some Fiscal Intermediaries strongly suggest (read: require) O/E dates. Expect vendors who mass produce assessment tools to include it.

The Overall Prognosis, Rehab Prognosis and Life Expectancy questions are being replaced with questions regarding Frailty and Stability. Influenza and pneumococcal vaccination status are being assessed. Another new question is one that assesses if the plan of care includes guidelines for physician notification in the plan of care.

Only one question regarding living arrangements is included in this section. A more in depth assessment is found at the end of the assessment.

Sensory Assessment

The current question regarding the patient’s ability to hear and understand spoken language has been split into two separate questions – one regarding ability to hear and the other regarding ability to understand verbal content. The vision question that we are familiar remains unchanged.

Like vision, the question regarding pain remains unchanged but three other questions regarding pain have been added to assess whether or not a standardized tool has been used to assess pain and the presence and effectiveness of any pain management measures.

Integumentary Status

One of the most significant changes in that only unhealed pressure ulcers are noted. Instead of trying to explain the question, I have cut and pasted below:

Note that for the first time we are being asked about the number of ulcers that were present on admission. And all the teaching that has been done regarding ‘back-staging’ ulcers will no longer be necessary since the data set specifies non-epithelialized ulcers.

The language regarding stasis ulcers has been changed slightly but the assessment remains the same. This is also the case with surgical wounds.

MO440 is gone at last. A new question in it’s place assesses if the patient has any skin lesion or open wound other than ulcers or surgical wounds that receiving assessment and/or intervention. Diabetic foot care has also warranted two new questions.

Respiratory Status and Cardiac Status

The respiratory status assessment remains unchanged.

Two new questions regarding congestive heart failure have been added. One question asks if the patient exhibited any signs of failure indicated ny clinical heart failure guidelines including dyspnea, orthopnea, edema, or weight gain at any point. The second question assesses what if any actions were taken by the staff.

Elimination

The questions regarding urinary incontinence are essentially unchanged with one major addition. The question assessing when urinary incontinence occurs now includes a response of ‘occasional stress incontinence’.

The bowel elimination/ostomy questions remain unchanged.

Neuro/Emotional Status

The questions regarding confusion, anxiety and cognitive function are unchanged. However, Depression is intensely assessed in the proposed OASIS-C. For instance, the data set asks if the patient has been assessed for depression using a standardized depression screening tool. It goes on to assess depressive symptoms reported or observed. Note this question is very much like the OASIS B-1 question with an important change in the order of responses. In the new data set, if the patient has no symptoms, the answer will be one. It also includes a response for ‘other’ signs or symptoms of depression. Two other questions follow investigating if there are interventions for depression.

ADLs/IADLs

In the published proposed data set there is no assessment of ‘prior’ ability – the patient status two weeks prior to admission for each point of assessment. Therefore, the responses of ‘unknown’ are not listed in the questions. However, there are two questions that investigate whether the patient is the same/better or worse at mobility and self car ability.

The questions regarding grooming, dressing upper and lower body, and bathing are the same. There are some changes in the question regarding toileting to specify that that toilet transferring is being assess. An additional question has been added to assess toileting hygiene which assesses if the patient is able to safely maintain perineal hygiene, adjust clothes and incontinence aids if used before and after using the toilet and cleaning and managing equipment.

The questions regarding transferring remains the same but an additional answer has been added to the question regarding Ambulation. The use of a one handed device as opposed to a two handed device (cane vs walker) is now assessed.

The question regarding feeding and eating is unchanged followed by the two questions regarding changes in mobility and self care ability referenced above.

Additional questions regarding fall risks are asked along with fall and fall risk interventions. A change in the ability to perform routine household tasks is assessed.

The questions regarding transportation, laundry and housekeeping do not appear to be in the proposed OASIS C data set.

Medications

The Medications assessment has been greatly expanded. A new question regarding the potential for adverse effects or reactions is asked first. Specifically, the question asks if the drug regimen review indicates a significant potential for adverse effects or reactions including ineffective drug therapy, side effects, drug interactions, duplicate therapy, omissions, dosage errors or non-compliance.

Next is a question investigating whether the MD was contacted within one calendar day to resolve clinically significant medication issues, including ‘reconciliation’. Two additional questions follow regarding patient and caregiver drug education.

The language in the question regarding patient ability to take oral, injectable and inhalant medications is slightly changed. The responses remain the same. There is an additional question that asks if the patient’s ability to take meds is better or worse than before the onset of illness that initiated the care episode.

Equipment Management

The question regarding the patient abilty to manage equipment remains unchanged but this section is where an in depth review the types and sources of the assistance the patient receives is assessed. Using a grid, the clinician is asked to evaluate the patients need for assistance in ADLs/IADLs, meds, other treatments or procedures, equipment management, supervision and advocacy. In the grid, responses assess whether or not assistance is needed and how likely the caregivers are to provide that assistance.

Therapy

The therapy question remains unchanged. It still requires the number of therapy visits the patient will receive.

Emergent Care

The question regarding whether or not the patient received emergent care has been reduced to a simple ‘yes’ or ‘no’ response with an option for ‘unknown’. The reason for Emergent care has been expanded from 9 possible responses on the OASIS B-1 data set to 19 on the proposed OASIS C data set.

The familiar discharge disposition question that assesses whether or not the patient remained in the community is followed by a second question assessing how much assistance the patient requires after discharge and who is providing the assistance.

The hospitalization question also remains the same but like Emergent Care, the responses have been changed to reflect more conditions and expand the definition of current responses.

The two last questions on the current OASIS B-1 data set requiring the date of last home visit and transfer date are not listed on the OASIS C data set.

For further details, please click on the link to the left on your screen and review the proposed OASIS C data set in its entirety.

As always, you can contact us at haydelconsulting@bellsouth.net.

Home Health, Hospice and Health Care Regulations

Posts from the ‘Home Health Physical Therapy’ Category

Update on OASIS-C Final Version

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We Need Your Help!

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Santa Baby

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Vendor or Provider?

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