On January 2, 2024, The Centers for Medicare and Medicaid Services (CMS) released a new, draft version of OASIS E1, which is to be used beginning January 1, 2025. The updated version of OASIS E is a result of a 2023 review of the data set by CMS with intention to identify items that did not meet criteria for inclusion.

For an item to be included in the OASIS data set it must either:

  1. Calculate a finalized measure for the Home Health Quality Reporting Program (HH QRP)
  2. Be used in the Home Health Prospective Payment System (HH PPS), currently PDGM
  3. Be used in the survey process for Medicare certification
  4. Be used to calculate a measure in the Home Health Value-Based Purchasing (HHVBP) demonstration
  5. Be used as a critical risk-adjustment factor and/or
  6. Be incorporated to fulfill a data category as part of the Home Health Conditions of Participation

For items to be removed or included in the data set, by law they must go through the CMS rulemaking process, meaning the proposed changes must be published with a public comment period before finalization. The 2024 Home Health Proposed Rule listed OASIS items that did not meet above criteria, along with CMS’ rationale for removal from the OASIS data beginning January 1, 2025. After the required comment period, CMS addressed any related public comments, and the proposed changes were finalized with the 2024 Home Health Final Rule.

The items being removed include: M0110 Episode Timing, M2200 Therapy Need, GG0130 and GG0170 Discharge Goals (DC) at Start of Care (SOC) and Resumption of Care (ROC).

While Medicare has not used M0110 or M2200 items since the implementation of PDGM in 2020, these items will not be missed by most Medicare-certified agencies. However, some private insurance companies or Medicare Advantage plans may still be using these items to calculate payment in an interim payment system. Agencies should identify which, if any, of their payers use these items for payment calculation in a prospective payment (Notice of Admission (NOA) and Final Claim) system and determine how the agency’s software system can capture this data moving forward.

The deletion of the DC Goal Column in GG0130 and GG0170 items is a result of the maxed out  “Application of Functional Assessment/Care Plan” quality process measure. Since home health agencies are meeting the requirement to include at least one DC goal (but can choose to include a goal for each item), quality monitoring among agencies is no longer meaningful. Therefore, the DC Goal column will be deleted in 2025.

This change will also align with the Home Health Value Based Purchasing (HHVBP) demonstration’s plans to include a new Discharge Function Score item from selected GG0130 and GG0170 items in 2025, rather than the Total Normalized Composite (TNC) Self-care and TNC Mobility scores currently used, which are based on the M1800 ADL/IADL items. The GG item’s DC Goal columns will not be needed for this HHVBP DC Function Score item; instead, an algorithm will be used to calculate the expected discharge status.

This generated score will be compared to the actual scores from the following items at the point of the Discharge OASIS being filed:

  • GG0130A, Eating
  • GG0130B Oral Hygiene
  • GG0130C Toileting Hygiene
  • GG0170A Roll Left and Right
  • GG0170C Lying to Sitting on Side of Bed
  • GG0170D Sit to Stand
  • GG0170E Chair/Bed-to-Chair Transfer
  • GG0170F Toilet Transfer
  • GG0170I Walk 10 Feet
  • GG0170J Walk 50 Feet With Two Turns
  • GG0170R Wheel 50 Feet With Two Turns

If the actual discharge status meets or exceeds the calculated expected discharge status there will be a positive outcome recognized.  In addition to use in HHVBP, these same items will be used in a publicly reported Care Compare outcomes measure by the same title:  Discharge Function Score, beginning in 2025. This January 1, 2025 refresh will use GG item data collected between April 1, 2023 – March 31, 2024.  As GG items become the norm for assessing functional status, accuracy of these “back burner” items is essential to agency health.

In addition to the item deletions slated for 2025, there is one item being added to OASIS E1 at Transfer, Death at Home and Discharge: O0350, Patient’s COVID-19 Vaccination is up to Date. This item’s intent is to collect data regarding the patient’s COVID-19 vaccination status at these specific timepoints. Clinicians will simply code either “0. No, patient is not up to date” or “1. Yes, patient is up to date”.

The Draft OASIS E1 Guidance Manual was published May 3, 2024 and directs the assessing clinician to review the medical record or documentation, and/or interview the patient, family or other caregivers or other healthcare providers to determine whether the patient is up to date with their COVID-19 vaccine. It states that vaccination status may be determined based on information from any available source. If the patient is not up to date, and the agency has vaccine available, ask the patient if they would like to receive the COVID-19 vaccine. The manual further directs providers to reference the Centers for Disease Control (CDC) website to determine whether the patient is up to date. Agencies should already be familiar with the CDC’s vaccination web site, which is referenced to determine influenza vaccination age and contraindication criteria.

Agencies should note that the published OASIS E1 Data Set is in draft version currently. Additional information will be available with the publication of the FINAL OASIS E1 Guidance Manual which is forthcoming. Additional changes may be introduced with the 2025 Proposed Rule as well. However, plans that address training of staff, software implementation timelines and payment delays during the transition to 2025 should be top of mind as the OASIS data set will impact Quality Reporting, Home Health Value Based Purchasing, and payment for some private insurance companies.

Agencies would be well served to budget resources for OASIS training to ensure assessing staff understand the intent and item guidance for these items, especially as they directly impact finances and partnerships with patients and insurance companies going forward.  Healthcare Provider Solutions offers Coding and OASIS training that equips home health staff with the education they need to empower your agency to achieve success. Learn more about our Coding Education and OASIS-E Education, today! HPS is here to assist your agency in preparation and training and will update with additional information as it becomes available.

Should you have questions regarding any of the outlined changes in the OASIS-E1 draft, or are interested in more information regarding our Coding and OASIS-E education, please feel free to reach out to us.

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