med-privacy in home health care: OASIS update & background (long)

[Peter Marshall <techdiff@ix.netcom.com>]

                              OASIS: What's New

ALERT: Delay in Mandatory Collection, Use, Encoding and
Transmission of OASIS (April 27, 1999)

On April 7, we notified you that the effective date of OASIS data
transmission was being delayed. In the following announcement, we would like
to further clarify that collecting and encoding OASIS information is also
affected. When the clearances referenced below are obtained, we will inform
you here as well as publish the appropriate related notices in the Federal
Register.

Delay in Mandatory Collection and Use

On January 25, 1999, we published a regulation (HCFA-3007-F, 64 FR 3764)
requiring all home health agencies (HHAs) participating in the
Medicare/Medicaid program to use a standardized assessment instrument,
Outcome and Assessment Information Set (OASIS), for all patients. This
requirement was in accordance with section 1891 of the Social Security Act,
and finalized a proposed rule published March 10, 1997 (62 FR 11004). The
goal of such mandatory use was so that HHAs could improve the quality of
their own services to patients. Mandatory collection and use by HHAs was to
begin on February 24, 1999.

In order for this mandate to be valid, we still need to obtain appropriate
clearances under the Paperwork Reduction Act. The completion of this
activity has been delayed, thus delaying the requirement that HHAs must use
the OASIS data set as part of their comprehensive assessment process. Upon
successful completion, we will issue a notification on the HCFA Internet
site (http://hcfa.gov) and publish a notice to this effect in the Federal
Register.

In the meantime, we are not requiring HHAs to use the OASIS instrument. HHAs
that were not meeting the requirements on or after the February 24 effective
date will not be held out of compliance. Of course, given that the
instrument was designed to be useful to HHAs to assess and improve the care
they furnish, they may wish to use the OASIS instrument for their own
purposes.

Delay in Mandatory Encoding and Transmission of OASIS Data

On January 25, 1999, we published an interim final regulation
(HCFA-3006-IFC, 64 FR 3748) mandating that all HHAs participating in the
Medicare/Medicaid program encode (that is, data enter) OASIS information in
a standard format and transmit it to HCFA as a condition of participation.
Encoding was to begin on March 26th and data transmission to the States on
April 26th.

In order for this mandate to be valid, we still need to obtain appropriate
clearances under the Paperwork Reduction Act, prepare and provide an
individual Privacy Act notice for patients, and publish a Privacy Act notice
of the existence and character of the OASIS system of records. The
completion of these activities has been delayed, thus delaying the
requirement that HHAs encode and transmit OASIS data. Upon their successful
completion, we will issue a notification on the HCFA Internet site
(http://hcfa.gov) and publish a notice to this effect in the Federal
Register.

In the meantime, we are not requiring HHAs to encode and transmit OASIS
data. HHAs that were not meeting the requirements on or after the above
effective dates will not be held out of compliance.

We will continue to post messages here concerning OASIS implementation.

[yellow ball]Y2K Certification Completed for Minimum Date Set (MDS) and
Outcome and Assessment Information Set (OASIS).

As of April 1, 1999 the MDS system, the OASIS system, and related software
programs have passed Millennium Compliance testing and are certified for
year 2000 compliance. (April 5, 1999)

To All OASIS Mailbox Users: (March 24, 1999)

Thank you for your e-mail. Your questions are now being reviewed and
answered by HCFA-contracted members of the OASIS team. Questions of a
sensitive or policy nature are reviewed by HCFA before responses are
returned to you. On a periodic basis, similar questions received through the
OASIS mailbox will be grouped and responded to as an update to our Questions
and Answers section elsewhere on this website. Please refer to this section
for the information that best represents your inquiry.

Inquiries related to data specifications and technical hardware and software
issues can be directed to the HAVEN help desk at: HAVEN_HELP@IFMC.ORG or
call 1-877-201-4721 from 7AM to 7PM (CT). We are sorry but we cannot answer
questions related to billing and reimbursement.


The OASIS Team

The final OASIS Regulations have been published! (January 26,1999)

Last Updated April 27, 1999



                            HCFA's OASIS Home Page

The purpose of this site is to store and disseminate policy and technical
information related to OASIS (the Outcome and Assessment Information Set)
data set for use in home health agencies (HHAs). The information posted here
is intended to assist HHAs, State agencies, software vendors, professional
associations and other Federal agencies in implementing and maintaining
OASIS.


                               OASIS Overview


---------------------------------------------------------------------Background
--

The Outcome and ASessment Information Set (OASIS) is a group of data
elements that:

*- represent core items of a comprehensive assessment for an adult home
care patient; and

*- form the basis for measuring patient outcomes for purposes of
outcome-based quality improvement (OBQI).

The OASIS is a key component of Medicare's partnership with the home care
industry to foster and monitor improved home health care outcomes and is
proposed to be an integral part of the revised Conditions of Participation
for Medicare-certified home health agencies (HHAs) - see the Regulations
page on this site.

The OASIS is currently being used in a national Outcome-Based Quality
Improvement (OBQI) demonstration involving 50 HHAs and in a single-State
demonstration project involving 22 HHAs. A slightly abbreviated form of the
OASIS is being used for quality improvement purposes in the national
Medicare prospective payment demonstration, including 90 HHAs in 5 States.
In addition, a substantial number of HHAs across the nation have elected to
begin incorporating the OASIS into their clinical record-keeping approaches.

Most data items in the OASIS were derived in the context of a HCFA-funded
national research program (co-funded by the Robert Wood Johnson Foundation)
to develop a system of outcome measures for home health care. This program,
and the OASIS, have evolved over a ten-year developmental period. The core
data items were refined through several iterations of clinical and empirical
research. Other items were added later by a work group of home care experts
to augment the outcome data set with selected items deemed essential for
patient assessment. The goal was not to produce a comprehensive assessment
instrument, but to provide a set of data items necessary for measuring
patient outcomes and essential for assessment - which HHAs in turn could
augment as they judge necessary. Overall, the OASIS items have utility for
outcome monitoring, clinical assessment, care planning, and other internal
agency-level applications.

Main Components and General Application --

OASIS data items encompass sociodemographic, environmental, support system,
health status, and functional status attributes of adult (nonmaternity)
patients. In addition, selected attributes of health service utilization are
included. These several different types of attributes should be part of a
comprehensive patient assessment, but we emphasize that the OASIS was not
developed as a comprehensive assessment tool.

In addition to measuring patient outcomes, OASIS data have three important
uses in the areas of:

*- patient assessment and care planning for individual adult patients;

*- agency-level case mix reports that contain aggregate statistics on
various patient characteristics such as demographic, health, or functional
status at start of care; and

*- internal HHA performance improvement.

All applications build on and are implemented most efficiently and
effectively when OASIS data items are thoroughly integrated into HHA
clinical documentation.

[Image]Using OASIS Items in Assessment and Care Planning --

Because most OASIS items describe patient health and functional status, they
are useful in assessing the care needs of adult patients. HHAs will find it
necessary to supplement the OASIS items in order to comprehensively assess
the health status and care needs of their patients (for example, the OASIS
does not include vital signs which are typically included in patient
assessments).

Clinicians have remarked that their first impression is that the OASIS data
set appears lengthy. However, they later acknowledge that its length is not
due to new items in addition to those HHAs currently use in their
assessments. Rather, it is due to the greater precision that characterizes
many of the items and simply requires more detailed descriptions of each
response. This precision is necessary to measure outcomes, which is the
primary purpose of the data set, but it also contributes to more precise
assessment of patient condition. Once clinicians become familiar with the
items, they generally find that assessment time does not change
significantly because a few new items are added, rather that existing items
are replaced with their OASIS counterparts.

The enhanced assessment is also useful in care planning, since it
facilitates identifying areas where patient status differs from optimal
health or functional status. As more precise assessments lead to improved
care planning, they in turn facilitate better care because clinicians can
more effectively focus on improving or maintaining current (precisely
measured) health status.

Requirements --

HCFA has finalized two rules relating to HHAs. One rule revises the existing
HHA Conditions of Participation by requiring that HHAs begin to collect
OASIS data. The other expands those new Conditions of Participation by
requiring HHAs to report OASIS to their State survey agency.

HHAs will be required to electronically transmit OASIS data to the standard
State system, which has already been installed by HCFA. HCFA will install
the additional software to accommodate this data transmission in each State.
The State agencies will have the overall responsibility for collecting OASIS
data in accordance with HCFA specifications. The State will also be
responsible for preparing OASIS data for retrieval by a central repository
to be established by HCFA.

One of the goals for OASIS automation is to fulfill the HHA provisions of
the Balanced Budget Act (BBA) of 1997. The BBA includes a Medicare
requirement for HHA prospective payment that depends on the data acquired by
the OASIS system. It is expected that this provision of the BBA will be
effective for HHAs' cost reporting periods beginning on or after October 1,
1999. Another HCFA goal is to provide States with enhanced ability to direct
on-site HHA inspection resources through the use of OASIS data. See OASIS
Regulations for details.


Last Updated March 3, 1999