On March 12, 2018, the Federal Register posted a Comment Request that included changing the OASIS data set. This is the next step in the process of updating to OASIS-D which CMS has scheduled for implementation on January 1, 2019.
What will be different?
Quite a bit, it seems. You can find the data elements finalized for removal from OASIS in the “Data elements finalized for removal in CY 2018 HH PPS Final Rule” document, at the bottom of the CMS OASIS Data Sets website in the Downloads section. CMS shows 235 total data elements are to be eliminated from the OASIS Start of Care (70 elements), Resumption of Care (70 elements), Follow-Up/Recertification (18 elements), Transfer to Inpatient Facility (42 elements), Death at Home (1 element), and Discharge from Agency (34 elements).
Additions to the 2019 OASIS-D data set will be fewer than planned. The list of new assessment questions in the “Proposed OASIS Items for CY 2018 HH PPS NPRM” and the proposed change table in the “OASIS 2019 Change Table for CY18 HH PPS NPRM” document at the bottom of the Home Health Quality Measures website in the Downloads section show the items that were planned for the new set. Of these items, only “Section GG: Functional Abilities and Goals”, and “Section J: Health Conditions” appear in the 2019 published set.
Unfortunately, this is not the last we will be hearing about additions to the OASIS. Most of the remaining proposed sections are planned to be released in 2020.
Why are they doing this?
The new OASIS items are actually not so new. They come from the MDS data set that is currently used in Nursing Homes. The addition of these items to the OASIS is another step toward compliance with the IMPACT Act and standardization of patient data between Long Term Care Hospitals, Inpatient Rehab Facilities, Skilled Nursing Homes and Home Health Agencies. This can help to recognize agencies that provide a high quality of care but it will also identify agencies who try to game the system by manipulating assessment responses to show higher outcomes.
What do I do now?
Review the 2019 OASIS-D data set. Now is the time to ensure that your voice is heard regarding these new OASIS items before they are finalized. You can go to the Federal Register’s Comment Request and submit any questions or concerns. CMS will analyze this input before the OASIS-D data set is finalized.
Start your planning for implementation soon. Reinforce education with clinical staff who may not understand completely how to answer the existing question GG0170C on the current OASIS. There will be a number of questions in the new data set with the same formatting so it is important that they answer both sections appropriately.
OASIS-D Revisions Visualized
To help you, we are supplying with this article our interpretation of the proposed changes for each OASIS. The parts in red are scheduled to be deleted from the data set and the sections in green could appear as new assessment questions.
- OASIS-C2 SOC to OASIS-D SOC
- OASIS-C2 Recertification to OASIS-D Recertification
- OASIS-C2 Discharge to OASIS-D Discharge
- OASIS-C2 Transfer to OASIS-D Transfer
- OASIS-C2 Death at Home to OASIS-D Death at Home
The comment period closes May 11, 2018 so keep that in mind if you do intend to provide input. And whatever the outcome, you can be sure that therapyBOSS will make any new data sets available to your clinicians by CMS’ final implementation date.