In the CY 2023 Home Health Final Rule, the Centers for Medicare and Medicaid (CMS) finalized the implementation of OASIS-E, going into effect January 1, 2023. According to CMS, the OASIS instrument was revised to increase standardization across post-acute care related to the IMPACT Act passed in 2014.

With the countdown to OASIS-E started, it is critical for organizations to educate their staff on the key elements and ensure they’re ready to take on these changes. A few significant areas of change will  include restructuring of the OASIS assessment, introduction of new Standardized Patient Assessment Data Elements (SPADEs), and the addition of assessments to evaluate mental status, mood and behavior. Let’s dive in and review the OASIS-E updates, the impact of these changes, and how your organization can best prepare.

The Key Elements to the OASIS-E Data Set

Under OASIS-E, you’ll find that there are several interview questions, such as race, ethnicity, language, etc., that will not require clinical decision making. Other OASIS items will require practice in order to achieve a level of comfort in determining the correct response, such as the Brief Interview of Mental Status (BIMS) (C0200-C0500), CAM (C1310), and the Patient Mood Interview (D0150). Below is an overview of new and updated OASIS items.

OASIS-ENew & Updated Items
Race & Ethnicity Items
  • Expands from 1 question to 2 separate questions
  • Many additional options have been added
Social Determinants of Health (SDoH)
  • Additional assessment items related to race, ethnicity, language, transportation, health literacy and social isolation all to be utilized by CMS for risk adjustment and mitigation of impacts on outcomes.
Transfer of Health Information
  • Adds 2 new quality measures for 2023:
    • Transfer of Health Information to Provider
    • Transfer of Health Information to Patient
  • Items A2120 – A2124 will help with tracking of the quality measures. These items also impacted the guidance associated with M2420 Discharge Disposition. Newer guidance on M2420 will also impact the value-based purchasing outcome.
Cognition & Mood
  • Adds BIMS, CAM, and PHQ 2-9
Medication Management
  • Adds N0415 High-Risk Drug Classes requiring an extra step in the Drug Regimen Review to identify drugs in certain classifications and investigating whether there is a patient-specific indication for the high-risk drug.
Pain Items
  • J0510, J0520 and J0530 replaces M1242 Frequency of Pain Interfering with Activity. These three new items identify whether there is pain interfering with sleep, therapy, and other activities.
Nutrition
  • Removes M1030 Therapies at Home and adds K0520 Nutritional Approaches to identify alternative nutritional therapies.
Special Treatments, Procedures & Programs
  • O0110 helps capture some of the complexities in patient treatments in all care settings.

The Impact on Reimbursement and Value-Based Purchasing

The new OASIS-E items will not impact reimbursement or Value-Based Purchasing (VBP) directly. PDGM reimbursement and VBP are determined by OASIS items that are in the current D1 version and those items will not change. However, they will play a large role in risk adjustment that will be utilized in the Total Performance Score related to VBP. Remember that ACH Acute Care Hospitalization (ACH) is 26.25% of our Total Performance Score. Given this information, our focus in home health should be preventing rehospitalization. Many of the new OASIS-E items will help identify patient needs and barriers for a more personalized plan of care and improved outcomes such as decreased hospitalizations and ED use.

How Does OASIS-E Impact your Organization?

OASIS-E changes will directly affect operations, care coordination, and patient outcomes due to the increased time to completion as well as new requirements for Transfer of Health Information. During the learning curve, organizations should expect their clinicians to spend more than usual time to complete the evaluation. The new Transfer of Health Information measures require a transmission of the reconciled medication list to the subsequent provider or patient and will occur at transfer and discharge. Each Agency must decide who or which department will have the responsibility to ready the medication list for delivery. This will improve care coordination and help organizations in Quality Reporting. As a reconciled medication list has shown to be a proven method for a smooth transition between care settings, this is a huge win and step towards improving patient safety, care coordination and promoting effective transitions of care between settings.

4 Steps to Prioritize Preparation

Just like any new process, to expect a successful transition, organizations must provide substantial support to their team. This is not a quick feat amid the ever-expanding expectations of the home health field clinician.  So how can your organization achieve this?

Educate your Staff

Engage in the many resources and learning opportunities out there related to OASIS-E. We recommend that you operationalize the gathering of information required in the new N0415 High-Risk Medications and O0110 Special Treatments, as they are high priority. Both items require a review of the medical record to identify all high-risk medications and all special treatments in the patient’s treatment plan, not just those provided in the home.

Be Realistic

Encourage your staff to share real-life scenarios to talk through during meetings and as they are happening. Holding a discussion on scenarios or challenges one clinician encounters may assist others in understanding the application of OASIS-E guidance.

Review, Review, Review

Monitor clinician documentation to ensure accuracy and consistency. Being able to provide clear feedback quickly reduces and prevents continued errors and enforces good habits moving forward. Additionally, set realistic expectations for your team and understand that adapting to change can take time.

Collaborate

Whether it is a discussion between nurses or an interdisciplinary team review, the clinician completing OASIS-E should have input from all staff that has contact with the patient during the assessment timeframe. Practice the BIMS, CAM and PHQ 2-9 with one another to become familiar with the language and how to properly administer the screening exams. CMS has provided sample language and simple cue cards in the OASIS-E manual.

Get Started Today

McBee experts continue to stress the importance of getting ahead of the learning curve and starting your transition sooner rather than later. Ensuring your staff has the resources and full support to correctly assess and code OASIS-E items will be critical to ensure a smooth transition into the new data set. While some organizations have adequate staff numbers and resources to transition well, some may find that their organization may not have the capacity to do so. Turning to a trusted partner, such as McBee OASIS Accuracy Services, is a great option. We aim to provide vital resources and education for OASIS-E and put you on the path to adapt, innovate and thrive through change.

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