With six months of adjustment to the 68,000 new health codes known collectively as ICD-10-CM now under its belt, the home health industry is buckling up for Round 2: six more months of new codes to assimilate, code revisions to integrate and new pre-claim reviews to handle.
More than 2,500 changes to the ICD-10-CM classification set are expected to be implemented Oct. 1: at least 1900 new codes, some 350 revised codes and more than 300 deleted codes. The Tabular List will change, some Excludes Notes will shift and others will disappear completely in this first reworking of the code set since its implementation at the first of this year.
While home health adapts to this newest version of the new classification set, agencies in at least 5 states will also grapple with rollouts of new pre-claim reviews changing the way they process claims for services. The Centers for Medicare and Medicaid Services (CMS) will require agencies in the affected states to secure prior authorization before processing claims.
Home health agencies in other states, expecting to soon be under the same requirement, will pay close attention to next month’s initial rollout in Illinois, as well as similar implementations in Florida on Oct. 1, Texas on Dec. 1, and both Michigan and Massachusetts on Jan. 1.
Don’t even think about muttering a “whew” under your breath — at least not yet. There won’t be any rest for the weary at the end of these next six months.
In fact, what’s in store next could possibly have one of the largest impacts yet on home health.
THE IMPACT OF OASIS C-2
It’s hard to overestimate the importance of the Outcome and Assessment Information Set, the CMS data collection tool known by the acronym OASIS, to a home health agency’s operation. This intake of information can affect patient outcomes, reimbursement, STAR ratings, Value Based Purchasing and an agency’s bottom line.
And it’s about to become even more important.
The revised version known as OASIS C-2 becomes effective on Jan. 1, 2017, ratcheting things up a few notches with the implementation of the first quality measures from the Impact Act of 2014. This Act establishes some standardized measures for easier reporting and sharing of data between skilled nursing facilities, long-term care hospitals, inpatient rehabilitation facilities and home health. The goal is to facilitate coordinated care and improve patient outcomes, providing better post-acute care for Medicare beneficiaries.
Some OASIS C-2 items, for example, are designed to help capture standardized reports of skin integrity, a patient’s functional status and cognitive function, medication reconciliation, incidence of major falls, transfer of health information and care preferences during a patient’s transition from one facility to another.
“As integral as OASIS has become to the success of home health agencies, it is only going to become more crucial in the future,” says J’non Griffin, owner of Home Health Solutions LLC. “Moving forward with the Impact Act initiatives in a value based environment, inaccuracy in OASIS reporting will cost agencies not only valuable dollars but also referrals. Providers will only want to partner with agencies that have excellent outcomes.”
In the five states selected for pre-claim review, OASIS C-2 will be one of a triad of components integral to set up patient eligibility and establish medical necessity. OASIS C-2 data will be used along with the patient’s comprehensive assessment and supporting documentation from the care provider to demonstrate why home health is necessary and support the pre- claim.
Home Health Solutions is offering assistance to agencies in the five initial states for reviewing and submitting those claims, and will expand the services to other states as needed. One of the first efforts the HHS team undertakes when working with agencies on their pre-claim reviews is stressing the importance of accurate OASIS completion.
Successful home health agencies, according to J’non, will be those who understand how crucial it is to collect OASIS information accurately, maintain effective and ongoing staff training and review to ensure continuity and efficient adaptation to changes, and develop a reliable system to bridge potential glitches such as those caused during periods of staff turnover.
Every employee needs training, every employee’s understanding of the material needs to be reviewed and every employee’s training needs to be updated regularly in order to maintain quality expectations.
“Because of the complexity and the frequency of changes not only in regulations but in the caregiver turnover in agencies, OASIS training is a continual education process,” J’non says. “Success can’t be achieved with a ‘one-and-done’ type training with clinicians.”
A LOOK AT C-2 CHANGES
The new version of OASIS will add several new items, including a GG-Functional section, and modify how some items are worded or numbered. Five items are revised and clarification is provided with regard to many of the questions submitted to the OASIS Help Desk. “In addition, there are some major wound guideline changes that could mean a significant decrease in case mix points,” J’non says.
Perhaps the most surprising change for many clinicians has been a startling change in how pressure ulcers are to be reported under OASIS C-2, but there are numerous other changes that will require clinicians to undergo a thorough training session in order to best adapt, J’non says.
She is putting the finishing touches on an all new online training session for OASIS C-2 which, while not yet available for purchase at the time of this post, is expected to be uploaded to the Home Health Solutions LLC Online Store within the next week to 10 days.
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