Updated OASIS-E Manual

The Centers for Medicare & Medicaid Services (CMS) has released a revised Outcome and  Assessment Information Set (OASIS-E) Manual with an associated Change Table. There are no changes to the OASIS-E instrument. 

The changes incorporate guidance into the manual and Q&As from the CMS Quarterly Q&As dated July 2022 through October 2023. 

Please see the two links below:

• Outcome and Assessment Information Set OASIS-E Manual (cms.gov)
• Change Table Summarizing 2024 Update to the OASIS-E Guidance Manual (cms.gov)

Industry Still in Shock Following Release of Home Health Final Rule

McKnight’s Home Care | By Adam Healy
 
Home health and hospice providers are still reeling from the release of last week’s home health rule. The regulation slapped home health providers with more Medicare cuts and finalized a Special Focus Program for hospices based on what providers believe is a flawed algorithm.
“It’s a punch in the gut, really, for providers,” Katie Smith Sloan, president and CEO of LeadingAge, said to McKnight’s Home Care Daily Pulse in a press conference at LeadingAge’s annual meeting. “And it’s really baffling to me that you can have an administration that says we need to support our older adults, we need to provide quality care, and yet we can cut reimbursement.”
 
The rule, released last Wednesday, included a permanent behavioral adjustment of -2.89%, prompting outcry from providers and advocates for the home health industry. These cuts came atop a permanent rate reduction of 3.925% this year, and many organizations like LeadingAge believe it may be too much for agencies to handle.
 
“It further squeezes the home health providers out there who are already struggling with workforce issues, increased costs,” Sloan said. “I have no idea what the thought process is. They clearly have done a disservice.”
 
How the cuts were implemented may unevenly affect providers of different sizes, markets or types, LeadingAge’s experts also said. 
 
“Doing it in aggregate means you’re treating all people equally,” Mollie Gurian, vice president of home based and HCBS policy at LeadingAge, said in an interview with McKnight’s Home Care Daily Pulse at the meeting. “Even whether their margins are 30% or whether their margins are 2% or negative. And it’s going to cause closures.”
 
The Special Focus Program for hospices also drew criticism for the algorithm that determines what providers are to be placed on the list. Since the provision was finalized without modification in the rule released last week, LeadingAge has explored ways to delay or prevent the SFP before it goes into effect on Jan. 1, 2024, according to Gurian.
 
“We’ve been strategizing about whether there’s a legislative approach that could help to delay it,” Gurian said. As to whether this possibility could be successful, “Probably not, but it’s worth trying, and I think we have support,” she said.
 
Luckily, CMS left room for further discussion, according to Katy Barnett, director of home care and hospice operations and policy, in an interview with McKnight’s Home Care Daily Pulse.
“There was some language in there after each of the sections finalizing the proposal that they really did clearly think that more conversation would be necessary,” Barnett said.
 
But if implemented, the SFP is expected to create a sort of “chilling effect” among providers, which might steer consumers away from unfairly-targeted hospices. It may not cause providers to halt hospice services, but it could reduce access to quality care, she noted.
 
“I don’t think it necessarily will drive providers out,” Gurian said. “I don’t think people will stop doing hospice because of the existence of a special focus program. But we do think if the wrong providers are identified, it could have a scarlet letter effect that is unfortunate … which would affect access ultimately.”

Home Health Providers Take Aim At CMS’ ‘Black Box’ Approach To Policymaking

Home Health Care News | By Joyce Famakinwa
 
Enough time has passed since the CY 2024 home health payment rule was finalized for providers to dive into its details, mull them over and respond. 
 
Though the rule is more favorable than the proposal the U.S. Centers for Medicare & Medicaid Services (CMS) first introduced in June, home health providers are not pleased with the final outcome. 
 
CMS didn’t address – and in some cases furthered – the concerns that many providers and industry stakeholders raised in the months and weeks leading up to the rule’s finalization. 
The rule comes with a 0.8%, or $140 million, aggregate increase to home health payments. In June, CMS proposed a 2.2% aggregate decrease for 2024, which would have been an aggregate decrease of $375 million. 
 
Plus, the rule finalized a -2.890% adjustment, which is half of the cut originally proposed back in June. 
 
“My initial reaction was that where we landed was an improvement over what was proposed,” Choice Health at Home CEO David Jackson told Home Health Care News. “I believe home health provides substantial economic upside for the Medicare program and for the beneficiaries. I continue to disagree with the methodology, as far as how it’s viewed as budget neutral.” 
 
When the rule was first released, some providers felt that relief. But that quickly wore off.
 
“I quickly came to the stark realization that CMS still was continuing with deep cuts — albeit they were kicking them down the road — despite the prevalence of respected third-party data highlighting that cuts have made problems with access to care a reality, not just an assumption,” David Totaro, chief government affairs officer at Bayada Home Health Care, told HHCN. 
 
Similar to Totaro and Jackson, other providers have voiced pushback to what they believe is CMS doubling down on its intention to implement the permanent adjustment cuts in the coming years. 

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Home Health Providers Are Beginning To Tie Clinician Compensation To Value-Based Care Success

Home Health Care News | By Patrick Filbin

Home health providers are adjusting their operations to be better set themselves up for value-based care.
 
One thing they need to be sure of, though, is that those adjustments are making their way down to the front line.
 
“From an agency standpoint, providers are thinking as their reimbursement model changes, how are we being judged against competitors and how are patients choosing us?” Jonathan Dickinson, senior manager of financial consultation with SimiTree, told Home Health Care News. “They’re noticing that a lot of it is based on quality. Value-based purchasing is going to impact their revenue. Now they’re starting to ask themselves, ‘How do we then incentivize our clinicians who are doing the work in the field to emphasize that quality?”
 
Operationally, providers are shifting to models – both inside fee for service and outside of it – that require better quality of care, sometimes with fewer visits.
 
But that message needs to make its way down to the frontline workers.
 
“Providers are saying, ‘You’re giving us great quality as a clinician — even though you may do 10 visits or less a month — we’re still going to pay you the same incentive,’” Dickinson said. “Because the quality is going to drive our reimbursement. We typically are seeing this more as a quality incentive around a quarterly bonus.”
 
For example, a provider could pay a clinician $30 for every visit after their goal in a quantity-based incentive program.
 
Now, providers are paying clinicians $10 for every additional visit and the other $20 is tied to quality incentives that go back to a patient’s outcome.
 
“If you have a clinician who continually just says, ‘I’m just going to do visits and not care about quality,’ they’ll still get a small portion of incentive and revenue, but it won’t be as big as if they were to actually drop back the number of visits and do more quality work,” Dickinson said.
To execute this type of plan, communication is paramount.
 
The more an agency can articulate how the quality of care is tied to compensation, job security and the overall health of the business, the better off everyone will be.
 
“The more an agency can correlate the fact that winning on value protects their jobs and allows them to have compensation increases, the more they’ll be able to understand how this actually impacts them,” Frontpoint Health CEO Brent Korte told HHCN. “It deeply impacts them.”
Based in Dallas, Frontpoint is a home health and hospice company that specifically tailors its business model to take on Medicare Advantage (MA) patients. It’s also betting big on value-based arrangements.
 
At the end of the day, agencies can’t pay clinicians more when they don’t have the money to spend, Korte said.

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