NAHC’s Intervention Aids in Halting OASIS Audit
July 11, 2014 02:01 PM
The Centers for Medicare & Medicaid Services (CMS) has informed the National Association for Home Care& Hospice (NAHC) that the Outcomeand Assessment Information Set(OASIS) submission audit conducted in the New England states has been suspended. CMS has instructed Strategic Health Solutions (SHS) to begin issuing record request cancellation letters to the providers from whom they have requested records.
In a recent NAHC Report article, NAHC reported that the Supplemental Medical Review Contractor (SMRC), SHS, had initiated an audit of home health agencies in New England states with a focus on OASIS assessments submitted in 2010. The audits were triggered by a recent OIG study that found a high incidence of Medicare paid claims where the home health agency did not have an accepted OASIS prior to the date of billing.
NAHC contacted CMS officials to discuss the validity and appropriateness of these audits. NAHC informed CMS of concerns that the audit included the re opening of claims that were 3-4 years past payment and that HHAs are not required to retain OASIS validation reports. CMS itself does not retain the validation reports beyond one year. In the audits, HHAs were at risk for retroactive claims denials because they could not produce the evidence necessary to demonstrate compliance.
Prior to CMS halting the audit, SHS had sent a second request for additional records to several agencies and informed the agencies that there may be a third request, since the project was to be conducted in three phases. One agency had received two requests for over 70 records each, 76 and 77 respectively, for a total of 153 records. Other agencies had received requests for over 30 records at each request.
Additionally, SHS was requesting the entire record with the intent to conduct an entire record review. NAHC contacted CMS again with this new development for which they informed NAHC that they will continue to look into the matter but had instructed SHS to cease with any additional record requests and to only require the OASIS validation documentation. However, when one provider attempted to submit only the OASIS validation documentation they were told by SHS that entire record was required and that the state OASIS repository can and will produce the validation reports.
After NAHC intervened again, CMS issued a complete halt to the audit.