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CoP Educational Series Part 3: Subpart B - Patient Care

Posted on Friday, July 7, 2017 4:49 PM

This post is the first of 3 covering Subpart B – Patient Care. This session will highlight the requirements surrounding OASIS data collection and submission, although there are minimal changes to these specific conditions regarding OASIS.  CoP 484.55 Comprehensive Assessment of Patients will also be outlined in this session.

The objective of this session is to identify requirements related to 484.40, 484.45 and 484.55.

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 an integral part of the revised Conditions of Participation for Medicare-certified home health agencies. Conditions 484.40 and 484.45 and the associated standards cover the release of patient identifiable information, including OASIS information and the reporting of OASIS information.

The Home Health Condition of Participation 484.40 (previously 484.11) – Release of patient identifiable outcome and assessment information set (OASIS) information has not changed with the revision and renumbering of the CoPs. The condition states the home health agency and any agent acting on the behalf of the agency in accordance with a written contract must ensure the confidentiality of all patient identifiable information contained in the clinical record, including OASIS data, and may not release patient identifiable information to the public. 

484.45 (previously 484.20) Reporting of OASIS information requires home health agencies to electronically report all OASIS data collected in accordance with CoP 484.55, Comprehensive Assessment of Patients.  The four standards associated with CoP 484.45 include:

a) Standard Encoding and transmitting OASIS data. Home health agencies must encode and electronically submit each completed OASIS assessment to the CMS system within 30 days of completing the assessment.
b) Standard Accuracy of encoded OASIS data. The encoded OASIS data must accurately reflect the patient’s status at the time of the assessment.
c) Standard Transmittal of OASIS data. The home health agency must:

1. Transmit the data for all completed assessments to the CMS collection site using electronic communications software that complies with the Federal Information Processing Standards. The reference to telephone connection has been removed from this standard.
2. Successfully transmit test data to the QIES ASAP System or to the CMS contractor.
3. Transmit data that includes the CMS-assigned branch ID as applicable.

d) Standard Data format. The home health agency must encode and transmit data using the software available from CMS or other software that conforms to the CMS standard electronic record layout, edit specifications, data dictionary, and that includes the current OASIS data set.

The Home Health Condition of Participation 484.55 Comprehensive Assessment of Patients states each patient must receive and the home health agency must provide a patient-specific comprehensive assessment. For those patients that are Medicare Beneficiaries, the agency must verify the patient’s eligibility for the Medicare home health benefit, including homebound status, both at the time of the initial assessment and the comprehensive assessment.

The standards associated with this CoP are:

a) Initial assessments of patients
b) Completion of the comprehensive assessment
c) Contents of the comprehensive assessment
d) Update of the comprehensive assessment

The requirements regarding initial assessments of the patients and the timing of this assessment has not changed. The same holds true for the completion of the comprehensive assessment. The contents of the comprehensive assessment, a new standard that incorporates elements from the current CoP including drug regimen review, incorporation of the OASIS data set and adds several new items.  This standard states the comprehensive assessment must accurately reflect the patient’s status and at a minimum must include the following information:

  • The patient’s current health, psychosocial, functional and cognitive status. This evaluation is to assist the home health agency in using this information in developing and implementing a patient-specific plan of care and so that agencies can potentially identify unmet patient needs that may need additional follow-up by another health care provider.  The intent of the evaluation of the cognitive status is to determine the extent in which the patient will be able to understand, remember and participate in the development and implementation of their own plan of care.  In general, it is felt there may be crossover between these items and items within the OASIS, although the items in the OASIS assessment may not always be sufficient for all patients.
  • The patient’s strengths, goals and care preferences including information that may be used to demonstrate the patients progress towards goals and measurable outcomes identified by the home health agency.
  • The continued need for home care services
  • The patient’s medical, nursing, rehabilitative, social and discharge needs
  • Full medication review to identify any potential adverse effects or drug reactions, identify ineffective drug therapy, significant side effects and/or drug interactions, duplicate drug therapy and non-compliance with drug regimen.
  • The comprehensive assessment must contain the patient’s primary caregiver, if any, and other available supports willingness and ability to provide care and their availability and schedules.
  • The patient’s representative/s if any.
  • Incorporation of the current version of the OASIS data set for all time points.

The last standard for this CoP is the requirement to update of the comprehensive assessment. The comprehensive assessment must be updated and revised (including the incorporation of the OASIS data set) as frequently as the patient’s condition warrants due to a major decline or improvement in the patient’s health status, but no less frequently than the last 5 days of every 60-day period starting with the start of care date unless there is a Beneficiary elected transfer, a significant change in the patient’s condition or a discharge and return to the home health agency within the 60-day period. 

The comprehensive assessment must also be updated within 48-hours of a patient’s return to the home from a hospital admission of 24-hours or greater for anything other than diagnostic testing or on a physician’s ordered resumption of care. Lastly, it must be updated on discharge.

Home Health CoP 484.50 – Patient Rights will be outlined in our next post. Be sure to check the Insights page next week.

Written by Peggy Patton, Vice President of Education Services

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