The big news in the latest proposed rule for HH PPS was the Home Health Groupings Model (HHGM). Along with the typical recalibration to case-mix payments and case weights, did you see the significant proposals regarding the Home Health Quality Reporting Program (HH QRP)? Almost a third of the 389 pages in the rule were in regard to the HH QRP.
Starting in CY 2019, CMS is proposing to remove 247 data elements from 35 OASIS items collected at each of the specific time points. They note that the data elements are not used in the quality measures or payments. Examples include M1011: Inpatient Diagnosis, M1025: Optional Diagnoses, M1410: Respiratory Treatments.
I wonder if this change alone suggests a new letter designation in the OASIS version or if C3 is next? CMS is also proposing beginning with the CY 2020 HH QRP to add three new cross setting measures required by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act:
- Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury.
- Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF# 0674).
- Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631).
Changes in Skin Integrity can be calculated from the existing OASIS items, but Falls with Major Injury would require two new standardized items to the OASIS for collection at End of Care (J1800: Falls, J1900: Number of Falls with no injury, minor or major injury ). It is the Functional Assessment that requires 15 new OASIS GG data items to reflect the additional mobility and self-care assessments to be measured.
CMS is also proposing collecting new standardized assessment data referenced in the IMPACT Act across each PAC settings in the following categories:
- Functional status, such as mobility and self-care at admission to a Post-Acute Care (PAC) provider and before discharge from a PAC provider;
- Cognitive function, such as ability to express and understand ideas, and mental status, such as depression and dementia;
- Special services, treatments and interventions such as the need for ventilator use, dialysis, chemotherapy, central line placement, and total parenteral nutrition;
- Medical conditions and comorbidities such as diabetes, congestive heart failure and pressure ulcers;
- Impairments, such as incontinence and an impaired ability to hear, see or swallow; and
- Other categories deemed necessary and appropriate by the Secretary.
There are an additional 22 items that CMS will apply across the PAC providers to allow for consistent definitions, most of which will require new OASIS items. The number of changing data fields proposed in the rule due to the IMPACT Act is extensive.
In one example for Vision, CMS is proposing to eliminate M1200: Vision as one of the 35 items that CMS is proposing to cut, but only to add another version that can be consistently applied across the PAC settings. In assessing options to standardize the vision impairment, the Skilled Nursing Multiple Data Set (MDS) 3.0 data element Vision: Ability to See in Adequate Light was chosen as the most reliable and accurate across the PAC settings.
There are many significant OASIS changes proposed in the HH QRP in this proposed rule. For more details, see Abt Associate’s report on the “Proposed Measure Specifications and Standardized Data Elements for CY 2018 HH QRP Notice of Proposed Rule Making" at: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/Proposed-Measure-Specifications-and-Standardized-Data-Elements-for-CY-2018-HH-QRP-Notice-of-Proposed-Rule-Making.pdf
So, what would you conclude – OASIS-C3 or D? I would go with “OASIS-D”.