NAHC Submits Comments on the OASIS C2
June 2, 2016 12:09 PM
On April 1, the Centers for Medicare & Medicaid Services (CMS) announcedin the FR a request for approval by the Office of Management and Budget and public comments for the Outcome and Assessment Information Set (OASIS)-C2/ICD-10. The OASIS-C2/ICD-10 is being modified to include changes pursuant to the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act).
This item set version is effective as of January 1, 2017, and includes the following changes:
Pursuant to the IMPACT ACT:
three new standardized items (M1028, M1060, GG0170c);
modification to and renumbering of select medication and integumentary items to standardize with other post-acute settings of care (M1311, M1313, M2001, M2003, and M2005).
Changes to the look back period and item number was changed in five items (M1500, M1510, M2015, M2300 and M2400).
converting multiple check boxes to a single box for data entry where responses are mutually-exclusive, and
changing the numbering for pressure ulcer staging from Roman to Arabic numerals.
The National Association for Home Care & Hospice (NAHC) raised concerns regarding the multiple applications (payment, value based purchasing, star ratings, and quality measure reporting) that the OASIS assessment instrument has for home health agencies. Noting that accuracy in completing the OASIS data set is imperative. Even minor changes to the OASIS will require additional training and could affect accuracy.
NAHC is also concerned that the requirements for cross setting measures and standardized assessment data could result in a lengthy assessment tool that will become very burdensome for agencies to administer. NAHC recommends that existing OASIS items be replaced or altered where duplication and/or overlap occurs.
A recommendation was offered to incorporate the revised the National Pressure Ulcer Advisory Panel (NPUAP) changes in terminology and updates that went into effect April, 2016.
And as usually, NAHC believes CMS has underestimated the burden for agencies in relation to the cost for training, collection and submission of the OASIS data set.
To view the comments click here.