Updates

Clarification on New OASIS Regulation for all Payer Sources 

The below question was presented to The CMS Home Health Quality Help Desk Team and CMS Home Health Value-Based Purchasing Help Desk Teams. Their response is noted below as well.

Question:

If a non-Medicare/non-Medicaid patient is on services with a home health agency prior to 01/01/25 will the home health agency be required to submit a SOC OASIS for that patient with a SOC date being 01/01/25 or after to meet the new requirement?

Or, for a non-Medicare/non-Medicaid patient that is on services prior to 01/01/25 not be included in the new requirement. Meaning, that since their actual SOC is prior to 01/01/25 no OASIS (including a new SOC) will be required for them in 2025 to meet the new requirement.

Response:

If a non-Medicare/non-Medicaid patient is on services with a home health agency prior to January 1, 2025 (i.e.; SOC date prior to January 1, 2025) an HHA may decide to complete OASIS assessments on this patient, but no OASIS SOC or subsequent OASIS should be submitted to iQIES for a non-Medicare/non-Medicaid patient with a Start of Care (SOC) prior to January 1, 2025, including any voluntary OASIS assessments completed in 2025.

Updates to the Home Health Quality Reporting Program

In October 2024, the data on the Care Compare site was refreshed. With this update, the Acute Care Hospitalization and Emergency Department measures were removed. These measures have traditionally been used for both Care Compare and the Home Health Value-Based Purchasing Program. 

The replacement is the Potentially Preventable Hospitalization (PPH) measure. This measure began being publicly reported in October 2024 and will be used in the Home Health Value-Based Purchasing (HHVBP) Model starting in January 2025. 

Preview reports for the January 2025 Care Compare refresh have also been released. Alongside the existing data on Care Compare, three new measures will begin public reporting in January 2025:   

• Transfer of Health Information to Patient 

• Transfer of Health Information to Provider 

• Discharge Function Score. 

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Another topic is the recent release (October/November 2024), of payment penalties for home health agencies that are not fully compliant with the Home Health Quality Reporting Program. This program requires participation in the Home Health CAHPS survey protocols and full compliance with data submission.  

A CMS-approved vendor to conduct your HHCAHPS surveys must be used. If your vendor fails to submit data properly, it will impact your compliance. It’s essential to ensure your vendor remains fully compliant with these submission requirements.

To avoid penalties in the Quality Reporting Program, ensure that 90% of your transmitted OASIS assessments are deemed Quality Assessments. A Quality Episode of Care includes the full span from admission to discharge or transfer, or Resumption of Care to discharge or transfer. To meet the criteria for Quality Assessments, both the Start of Care or Resumption of Care as well as a transfer or discharge need to be submitted. 

If all your Starts of Care have been submitted but only 50% of your discharges, your agency will be found non-compliant. For compliance, 90% of all assessments need to qualify as Quality Assessments, meaning each episode must have both a start and an end. 

If you were not fully compliant with the Home Health Quality Reporting Program in 2023, your October 2024 report will have reflected this noncompliance, resulting in a 2% penalty applied to your 2025 Annual Payment Update. This means payments for services provided in 2025 will include a 2% reduction. Unfortunately, the deadline to file a reconsideration via mail was November 27, 2024.

HHA Provider Report Enhancements 

On November 12, 2024, enhancements were applied to some Home Health Agency (HHA) on-demand provider-level reports, which are available in the Provider report category in the Internet Quality Improvement and Evaluation System (iQIES). The reports that were enhanced are listed below:

1. HHA Activity Report

2. HHA Discharge Report

3. HHA Error Summary by Agency Report

4. HHA Roster Report

5. OASIS Error Detail Report

Below is a list of reports and the enhancements that have been applied:

• Reports are now available in Portable Document Format (PDF), in addition to the existing online or Hypertext Markup Language (HTML) and Comma Separated Value (CSV) formats.

  • This enhancement applies to all reports.

• Additional sorting was applied to include sorting by patient last name and patient first name. This enhancement applies to the following reports:

  • HHA Activity Report

  • HHA Discharge Report

  • HHA Roster Report

• Asterisks (*) will display when empty values are present in the report and an informational note about the asterisk has been added to the report.

  • This enhancement applies to all reports.

• A message indicating “No Data Returned for Selected Criteria” will display if no records are returned from the report request.

  • This enhancement applies to all reports.

• Leading zeroes (0) will display the CCN and Agency ID values in the CSV file, when applicable.

  • This enhancement applies to all reports.

• A Total Counts column has been added to the CSV reports to align with the HTML and PDF outputs.

  • HHA Activity Report

  • HHA Discharge Report

  • HHA Roster Report

• The enhancements below apply specifically to the OASIS Error Detail Report.

  • The number of errors allowed for each report request is limited to five.

  • An “Error Numbers Selected” field has been added to the report and displays the specific errors for which the report was generated.