CMS Proposes Noteworthy Changes to OASIS

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By Terry Miller, RN 
Regulatory Advisor, McKesson

OASIS Updates Impact Home Health CareIn June, CMS proposed changes to OASIS data that, if implemented, would affect all home health providers who accept Medicare. The implementation of OASIS C1 would coincide with the implementation of ICD-10 on October 1, 2014.

Per CMS, the proposed revisions to OASIS-C1 include:

  1. Revising OASIS items to enable the coding of diagnoses using the ICD-10-CM coding set, which goes into effect October 1, 2014.
  2. Addressing issues raised by stakeholders, such as updating clinical concepts and modifying item wording and response categories to improve item clarity.
  3. Reducing the burden associated with OASIS data collection by removing items not currently used by CMS for payment, quality or risk adjustment.

Here are several noteworthy proposed changes:

  • Elimination of M1012 Inpatient procedure
  • Changes to numbering of M items where responses or expansion has been made to accommodate character requirements
  • M1310 Pressure Ulcer length, M1312 Pressure Ulcer width and M1314 Pressure Ulcer depth collection has been deleted from all time points
  • M1350 Skin lesion or open wound, collection time points have changed, collect only at Start of Care (SOC) and Resumption of Care (ROC)
  • M1410 Respiratory treatment collection time point changed to collect only at SOC and ROC
  • M2110 Frequency of ADL or IADL assistance collection time point changed to collect only at SOC and ROC
  • Elimination of M2440 reason/s for nursing home admission

In its proposal, CMS states that OASIS C1 will reduce the burden on home health providers because the proposed change would reduce the number of M items in the data set from 114 (in OASIS C) to 110 (in OASIS C1). SOC items change from 95 to 91; ROC items from 80 to 76; the transfer to inpatient care items from 19 to 18; and the discharge items from 61 to 55. The number of items collected at recertification/follow-up is anticipated to remain the same: M1350 is deleted for that time point, but M1011 is added to be collected for the purpose of case-mix adjustment used in the home health PPS.

Significant changes to OASIS and the impending ICD-10 changeover both point to the need for a robust  home health software solution that can relieve much of the burden of complying with ever-changing regulations. As McKesson Homecare™ customers know, we’re targeting to release updates to accommodate the OASIS C1 well in advance of the October 2014 deadline.

At this point, we’re just waiting for CMS to issue the final rule. The comment period has passed, so that final rule likely will be issued in the next several months.

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