CMS Announces Plans for OASIS–C1 Related to the ICD-10 Delay
May 22, 2014 03:01 PM
On April 1, 2014, the Protecting Access to Medicare Act of 2014 (PAMA) (Pub. L. No. 113-93) was enacted, which stated that the Secretary may not adopt ICD-10 prior to October 1, 2015. CMS has spent several weeks assessing what, if any, impact this ICD-10 delay will have for our various quality reporting programs.
NAHC has determined that the ICD-10 delay will have an impact on the Home Health Quality Reporting Program and more specifically on the implementation of OASIS-C1.
A new version of the OASIS-C1 data item set is scheduled for implementation on October 1, 2014. However, five (5) of the data items contained in OASIS-C1 require the use ICD-10 codes. Because ICD-10 has been delayed until at least October 1, 2015, it is now necessary to make interim changes to the OASIS-C1 data items set and also the process used for reporting OASIS-C1 data to CMS.
The following is a summary of the changes that CMS will be making in the Home Health Quality Reporting Program in response to the legislatively mandated ICD-10 delay:
A. OASIS-C1 Implementation
A modified version of OASIS-C1 will be created, in which the 5 items that use ICD-10 codes (i.e. - M1011, M1017, M1021, M1023, M1025) will be replaced with the corresponding ICD-9 based items from OASIS-C (i.e. – M1010, M1016, M1020, M1022, M1024).
This modified version of OASIS-C1 data set that will be referred to as “OASIS-C1/ ICD-9 Version.”
The current version of OASIS (OASIS-C) data set will remain in effect until 11:59:59 p.m. on December 31, 2014;
The OASIS-C1 / ICD-9 version will go into effect at 12:00 a.m. on January 1, 2015 and shall remain in effect until ICD-10 is implemented or until otherwise determined by CMS;
B. Conversion To Assessment Submission and Processing (ASAP) System
OASIS submissions to the state system will discontinue starting at 6:00 p.m. ET on December 26, 2014. The HHA state submission system will no longer be used for OASIS submissions. New, modification, or inactivation records in the current flat file format must be submitted prior to 6:00 p.m. ET on December 26, 2014.
Effective January 1, 2015, OASIS assessment data will be submitted to CMS via the Assessment Submission and Processing (ASAP) system. With the implementation of the OASIS ASAP system, Home Health Agencies will no longer submit OASIS assessment data to CMS via their state databases.
C. Payment Grouper Updates
An updated home health payment grouper will be released on October 1, 2014 to accommodate assessment submitted October 1, 2014 and later using OASIS-C and ICD-9-CM codes;
An updated home health payment grouper will be released on January 1, 2015 to accommodate assessments submitted January 1, 2015 and later using OASIS-C1 and ICD-9-CM codes;
At this time, a new home health payment grouper update is not planned until October 1, 2015.
The final form and guidance manual are in the clearance process now. When finalized, they will be posted here.
The Division of Continuing Care Providers will be rescheduling a previously planned webinar. The tentative date is September 3, 2014 at 2:00PM Eastern. A Survey and Certification letter (S&C letter) will be issued with final details.