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Return to BQA memo 00-083

DEPARTMENT OF HEALTH & HUMAN SERVICES
Health Care Financing Administration
Center for Medicaid and State Operations
7500 Security Boulevard
Baltimore, MD 21244-1850

DATE: November 20, 2000

FROM: Director, Survey and Certification Group, Center for Medicaid and State Operations

SUBJECT: Outcome and Assessment Information Set (OASIS) Timing Requirements—INFORMATION

TO:  Home Health Agency OASIS Submission Staff, State Agency OASIS Educational Coordinators, State Agency OASIS Automation Coordinators

 The purpose of this memorandum is to provide guidance to Home Health Agencies (HHAs) and State survey agencies concerning OASIS timing requirements during the transition period into the home health Prospective Payment System (PPS).

The Final Rule for PPS published in the Federal Register (exit DHFS) (65 FR 41128) on July 3, 2000, revised the timing requirements for the scheduling of OASIS follow-up assessments. Specifically, on page 41221, the OASIS timing schedule was changed from an interval requiring a follow-up assessment every two months to a 60-day assessment schedule.

This revised assessment interval will cause warning messages related to timing on OASIS follow-up assessment records to appear on the validation report produced by the State when the assessment is submitted for patients with a start of care prior to October 1, 2000.

The warning message results from the fact that the software will calculate due dates for follow-up assessments according to the new 60-day follow-up schedule, regardless of whether the start of care date is before or after October 1, 2000. In this situation, the warnings can be ignored with no consequence to the HHA.

The specific warning message generated by the State system (message number 262) cautions that the follow-up assessment completion date (M0090) does not meet the Health Care Financing Administration (HCFA) 60-day timing guidelines. The system edit that determines whether to generate this warning message considers the 60-day follow-up assessment schedule only. It is unable to consider the two-month schedule in effect prior to October 1, 2000. For that reason, the message can be ignored.

Note that the situation is unique to patients already on service prior to October 1, 2000, who are involved in the transition from one regulatory time frame (every 2 calendar months) to another (every 60 days). Generally speaking, HCFA does not encourage HHAs to ignore warning messages; however, in this exceptional situation, the warning message is unavoidable. Patients admitted to the HHA after October 1, 2000, and who remain on service beyond a single 60-day episode, are expected to be re-assessed with OASIS follow-up data collected during the last 5 days of the current 60-day period, based on the start of care date. In this case, a warning message indicating deviation from the required time frame for collection of OASIS follow-up data would be valid and a cause for the HHA to examine its follow-up data collection schedule.

HCFA is providing this memorandum for those who require documentation in addition to information provided on HCFA's web pages. We recognize the concern that a warning message may cause in the circumstances described above. For more information, please consult the HCFA OASIS web page at http://www.hcfa.gov/medicaid/oasis/oasishmp.htm [changed to http://cms.hhs.gov/oasis/hhoview.asp (exit DHFS)] and particularly information related to the transition to PPS at http://www.hcfa/gov/medicaid/oasis/oasispps.htm. [no longer operable]

If you have any questions about these instructions, please contact your State OASIS Educational Coordinator or State OASIS Automation Coordinator.

/s/ Steven A. Pelovitz