Another Successful Blueprint for OASIS Training & Exam


The Home Care Alliance of MA would like to thank the over 85 participants who took to the 2-day intensive Blueprint for OASIS training as well as a special congratulations to the 54 participants that took the OASIS COS-C certification exam last week on Wednesday, March 16th in Milford, MA.

Although OASIS is a high demand training, especially with the benefits to Value Based Purchasing, there is still a large cost associated with putting the training on. HCA would like to hold another training in the fall for members, around roughly November, however, we need to know if members would be interested in attending. With that, whether you are interested or not, the association would greatly appreciate it if you could take this very quick survey with your thoughts.

Your feedback is very valuable to us!

For any questions please feel free to contact Megan Fournier at or 617-482-8830.

Government Shutdown Delays Quarterly OASIS Q&As

Due to the government shutdown, the CMS OASIS Quarterly Q&As will not be released on October 16, 2013 as previously expected. As soon as the government reopens for business, the Q&A release will be rescheduled and the HCA will post the results in our Update

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New OASIS Q&As Released

The July Q&As are here!

CMS has just released the latest guidance for OASIS, July 2013 Quarterly Q&As.  This quarterly update contains 16 new question and answers including guidance related to:

  • Observation stays-When a patient is in observation status at a hospital past day 60 of the current episode, treat this event as a missed recertification and complete the recertification as soon as possible after the patient returns home
  • M1055- clarifying the response if an agency does not immunize patients
  • Clarification to multiple questions related to pressure ulcers and surgical wounds
  • Clarifying time frames in multiple M-items
    • M1240- time frame used to assess pain,
    • M1620 time frame when to assess bowel incontinence and
    • Clarification to M1242, Response 4 – “All the time”
  • Timely resumption of care (ROC)-when a ROC OASIS is done outside the required 48-hour time frame, clinicians must answer “no” to several best practice questions:
    • M1240 (Pain assessment),
    • M1300 (Pressure ulcer risk assessment),
    •  M1730 (Depression screening),
    •  M1910 (Falls risk assessment) and
    • M2250 (Plan of care synopsis).-if a best practice listed under M2250 is not applicable to the patient, answer “NA.”

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OASIS-C1 is Here!

CMS has issued a Notice in the June 21st Federal Register announcing the proposed version of the OASIS–C1.  This draft of OASIS C-1 has 110 items and reflects changes to accommodate the need to enable the coding of diagnoses using the ICD-10-CM coding set which goes into effect October 1, 2014. The draft also reflects changes to address issues raised by stakeholders, such as updating clinical concepts and modifying item wording and response categories to improve item clarity; and to reduce burden associated with OASIS data collection by removing items not currently used by CMS for payment, quality, or risk adjustment. The draft also adds one new item M1011 (Inpatient diagnosis) at Recertification/Follow-up for the purposes of potential case-mix adjustment.

Comments on the draft OASIS-C1 must be received by August 20, 2013. When commenting,  reference the document identifier or OMB control number (OCN). To be assured consideration, comments and recommendations must be submitted in any one of the following ways:

  1. Electronically.

You may send your comments electronically to Follow the instructions for ‘‘Comment or Submission’’ or ‘‘More Search Options’’ to find the information collection document(s) that are accepting comments.

  1. By regular mail.

You may mail written comments to the following address:

CMS, Office of Strategic Operations and Regulatory Affairs,

Division of Regulations Development,

Attention: Document Identifier/OMB Control Number__ Room C4–26–05,

7500 Security Boulevard, Baltimore,

Maryland 21244–1850.

The revised instrument, a table that compares the OASIS-C (Current Version) to the OASIS-C1 (Proposed Data Collection), and the supporting documentation can be found on CMS Paperwork Reduction Act (PRA) listing page, click here and scroll to CMS-R-245.

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New OASIS Guidance from CMS

CMS has just released the latest guidance for OASIS, October 2012 Quarterly Q&As.  This quarterly update contains 11 new Q&As including the latest CMS OASIS-C guidance with a special item about selecting fall risk assessment tools based on standardization, validation and multi-factor requirements.Other highlighted items:

  • situations where the physician-ordered ROC date is outside the assessment time frame
  • selecting a response for patient confusion when confusion level varies
  • how/when bipolar disease and other psychiatric diagnoses might impact the depression process measure.

Be Prepared: Audit Activity on the Increase

Locally, regionally and across the nation, home care agencies are reporting increased federal scrutiny.  Every agency should be especially attentive to regulatory compliance.

The Boston Office of the HHS Inspector General is visiting many agencies across New England to conduct an audit of OASIS processes, with a focus on proper and timely submission of the OASIS to the state. They are looking closely at evidence of the OASIS transmission to the State before the submission of the claim, as well as at each agency’s process to review “fatal errors” and validation reports. We believe as many as 70 agencies may ultimately be asked for records.  We have not heard of any results or payment penalties as yet as a result of these audits.

Agencies also report that as a result of the submission of their Medicare Provider Enrollment Application (CMS 855a), federal inspectors are visiting on site to verify – often with camera’s – that the physical address reported on the form is operational.

Finally, it appears the ZPIC – Zone Program Integrity Contractors – are moving into home health. Unlike RACs which just look at  overpayment issues, the ZPICs are tasked with assisting HHS in discovering fraudulent practices.  A fairly detailed legal explanation of the roles of these federal contractors can be found here.

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