Overview

On October 6, 2014, the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act) was signed into law. The Act requires the submission of standardized data by post-acute providers, including Home Health Agencies. The Outcome and Assessment Information Set (OASIS) will collect standardized data for Home Health Agencies.

The IMPACT Act requires reporting standardized patient assessment data regarding quality measures and standardized patient assessment data elements (SPADEs). The Act also requires the submission of data pertaining to measure domains related to resource use and other domains. In addition, the IMPACT Act requires assessment data to be standardized and interoperable to allow for the exchange of the data among post-acute providers and other providers. The Act intends for standardized post-acute care data to improve Medicare beneficiary outcomes through shared decision-making, care coordination, and enhanced discharge planning.

The Meaningful Measure priority areas are

Promote effective communication and coordination of care
Promote effective prevention and treatment of chronic disease
Work with communities to promote best practices of healthy living
Make care affordable
Make care safer by reducing harm and cost in the delivery of care
Strengthen person and family engagement as partners in their care

Quality Measure Domains

Skin integrity and changes in skin integrity
Functional status, cognitive function, and changes in function and cognitive function
Medication reconciliation
Incidence of major falls
Transfer of health information and care preferences when an individual transitions

Resource Use and Other Measure Domains

Resource use measures, including total estimated Medicare spending per beneficiary,
Discharge to community, and,
All-condition risk-adjusted potentially preventable hospital readmissions rates.

Assessment Categories

Functional status
Cognitive function and mental status
Special services, treatments, and interventions
Medical conditions and co-morbidities
Impairments
Other categories required by the Secretary

CMS introduced OASIS-E changes for Home Health Agencies to meet the requirements of the IMPACT Act and improve interoperability among the post-acute continuum. After delaying the implementation of OASIS-E changes due to the COVID-19 Public Health Emergency, CMS has announced that Home Health Agencies should implement OASIS-E changes by January 1, 2023. Home Health Agencies should understand the extent of OASIS-E changes.

In this blog, we will review OASIS-E changes, the impact of these changes, and how the agencies should prepare for these changes before OASIS E effective date.

OASIS-E Changes

OASIS-E changes represent the most significant changes since OASIS was introduced in 1999. OASIS-E changes will standardize patient assessment data elements, facilitate the exchange of information, submission of Quality Measures and improve patient outcomes.

The following are the significant areas of OASIS-E changes.

Restructuring of OASIS assessment
Introducing new elements to meet Standardized Patient Assessment Data Elements (SPADEs)
New assessments to assess Mental Status, Mood, Behavior, etc.

OASIS Assessment Restructure

OASIS Sections have been reorganized to align with other post-acute standard patient assessments like Minimum Data Set (MDS) for Skilled Nursing Facilities. Sections have been named from A (Administrative) to Q (Participation in Assessment and Goal Setting). New elements and current OASIS-D1 elements have been grouped under these sections.

The following are OASIS-E sections.

A - Administrative Section

B - Hearing, Speech, and Vision

C - Cognitive Patterns

D - Mood

E - Behavior

F - Preferences for Customary Routine Activities

G - Functional Status

GG - Functional Abilities

H - Bladder and Bowel

I - Active Diagnoses

J - Health Conditions

K - Swallowing/nutritional status

M - Skin Conditions

N - Medications

O - Special treatment, Procedures, Programs

Q - Participation in Assessment and Goal Setting

OASIS-E Assessment Elements:

OASIS-E element changes include introducing new elements, removing current OASIS elements, and reorganizing these elements under the new sections. Some of the guidance for existing elements have also been changed. The naming convention and the structure of new elements match the patient assessment elements in other post-acute settings.

The following is the summary of OASIS-E Assessment Element changes.

	
			Type
			Elements in OASIS-D1
			Elements Added in OASIS-E
			Elements Removed in OASIS-E
			Change
			Elements in OASIS-E
		

	
			Start of Care assessment
			158
			59



			14
			45


			203
		

			Resumption of Care
			131
			49
			8
			41
			172



		

			Follow Up
			36
			8
			0
			8
			44
		

			Transfer
			22
			1
			1
			0
			22
		

			Death at Home
			9
			0
			0
			0
			9
		

			Discharge
			97
			51
			2
			49
			146
		

New Assessments

OASIS-E has introduced new assessment areas to assess patients to meet IMPACT Act requirements. The following are the areas of new assessments.

Reconciled Medication List and Transfer (Section A)
Cognitive Patterns (Section C)
Signs and Symptoms of Delirium from CAM (Section C)
Mood – Expand PHQ-2 to PHQ09

Refer to the following link for more information on OASIS-E sections and elements.

https://www.cms.gov/files/document/draft-oasis-e-all-items03122020.pdf.

SHP Data has provided a handy crosswalk guide between OASIS-D1 and OASIS-E elements. Use the following link to access the crosswalk.

https://www.shpdata.com/media/2199/shp-oasis-d1-to-oasis-e-crosswalk-20.pdf

OASIS-E Impact

OASIS-E changes will directly impact Home Health Agency operations, quality of care, and patient outcomes. The following are some of the areas of impact:

Completion Time: Introduction of new sections, elements, and assessments will increase clinicians' time completing the assessments. CMS estimates that it will take additional 2.5 minutes to complete the evaluation once the clinicians are familiar with the changes. Home Health Agencies should expect their clinicians to spend more than 2.5 minutes to complete the evaluation initially.
Interoperability: OASIS-E changes are consistent with IMPACT Act requirements to improve interoperability. Using Standardized Patient Assessment Data Elements (SPADEs) across all post-acute care settings, including Home Health, will enhance interoperability and improve the quality of care and patient safety.
Transfer of Health: Introduction of Reconciled Medication List and Transmission to Subsequent Provider or patient at Transfer and Discharge will improve care coordination. This will also help Home Health Agencies in Quality Reporting.

Preparation for Agencies

OASIS-E represents the most significant changes to OASIS since its introduction. Home Health Agencies will need to modify the operations process and leverage electronic health records (EHR) to meet the challenges posed by OASIS-E changes.

Education and Training: Education and training can enable Home Health Agencies to stay ahead of the changes coming in 2023. Many national and state organizations are providing educational and training sessions for OASIS-E. Engaging your clinical team in these opportunities will prepare the team to get ready for these changes.

Policies and Procedures: Review the current policies and procedures and make changes to accommodate the new changes. Developing a process to review the documentation requirements and consistency will help agencies with the HHVBP model.

Software Platform: The software platform will play a critical role in helping Home Health Agencies to meet the challenges of OASIS-E changes. Agencies should check with their software vendors to understand their plans to accommodate OASIS-E, make sure their project will meet the requirements, and adjust their process accordingly

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