Back on December 23, 2005, CMS published a new OASIS reporting regulation that is due to go into effect today. Under the revised regulation, the requirement to lock OASIS data was removed. This allowed HHAs to change their OASIS data without receiving an edit warning. However, without the lock, you would have to transmit your OASIS data before you could submit a request for anticipated payment ("RAP"). This created the potential for more frequent OASIS transmissions in order to submit RAPs. CMS has now decided to allow HHAs to continue "locking" their data in order to transmit RAPs before submitting OASIS data.
CMS (after prodding from NAHC) has offered three ways to do this:
Option 1 - Continue to Use Software Other than HAVEN That Locks AssessmentsIf your HHA billing software is integrated with OASIS data and contains an internal locking feature, you may continue to use that locking feature. You may continue to submit RAPs when that data is locked. If your software has not been changed in anticipation of OASIS changes, this option will mean no change to your current process is necessary.
Option 2 - Continue Using HAVEN 6.2 (version 1.40) Software to Lock AssessmentsWhen your HHA receives HAVEN 7.0 (version 1.50), you may choose not to install this new software. You may continue to lock and transmit data using HAVEN 6.2 (version 1.40), submitting RAPs when the data is locked. CMS has analyzed the short term impact of HHAs continuing to use HAVEN 6.2 (version 1.40). There will be a small number of records that were previously accepted that will now be rejected due to inconsistencies among the pressure ulcer, stasis ulcer, or surgical wound items. These records can be corrected by the user and re-submitted. New warnings will be issued if the record is submitted more than 30 days after the completion date or if there is an inconsistency between the primary diagnosis code and severity code. Otherwise, these HHAs will be unaffected by not implementing HAVEN 7.0 (version 1.50) in the short term.Agencies who continue to use HAVEN 6.2 in the short term must be aware that this software does not support the submission of a National Provider Identifier (NPI). Therefore it cannot be used on or after the NPI effective date of May 23, 2007. You should migrate to HAVEN 7.0 or begin to use other software that includes a lock feature by May 22, 2007.
Option 3 ? Migrate to HAVEN 7.0 (version 1.50)Upon receipt of HAVEN 7.0 (version 1.50) software, your HHA may choose to install that software. If you do so, you will need an agency procedure to ensure that all assessments are in a "Locked (Export Ready)" status before submitting the corresponding RAP.
If your HHA has already made changes to your software to remove the OASIS lock date and the locking function, you should temporarily develop internal procedures for establishing that OASIS data is finalized for transmission to the State, equivalent to the prior state of being locked, before submitting your RAPs. This internal procedure should include a date the OASIS data was finalized, which could be compared to the dates of submission of RAPs in any future audit of your records. As soon as possible you should revise your processes to use one of the compliant options described above.
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I heard from one of the Home Health trade associations that the National Association for Home Care ("NAHC") has issued an update regarding the HHABN situation. For the most part, the release summarizes what has already happened. (Which isn't surprising, because there has not been a whole lot new to report.) Having said that, the update does offer some new tidbits.
According to the update. the Centers for Medicare and Medicaid Services ("CMS") are still looking at fall for the new HHABN "rollout", even after the recent filing by the plaintiffs. According to NAHC, CMS intends to comply with the Paperwork Reduction Act requirements in releasing the next proposed HHABN. This means that there will be a thirty-day comment period after the revised HHABN is issued. CMS intends to issue the new HHABN in the next few weeks.
Based on this timeline, CMS intends that the new HHABN will not be implemented until early fall.
CMS's intentions depend upon the ruling from the District Court on the Plaintiffs' recent motion to the Court, which requested the Court order compliance by July 1. CMS?s deadline for responding is June 21, 2006. This means that the Court may not rule before next week. (Of course, the Court could rule tomorrow, you just never know with courts.)
NAHC continues to try to become involved in the litigation as either a party or a friend of the Court. NAHC is taking the position that the plaintiffs? request for an injunction is an attempt to preempt the rights of the public to comment on any proposed paperwork requirements. (Which is true.) It will be interesting to see what, if anything, the Court has to say about the providers? rights and the administrative requirements CMS must obey.
Keep in mind, the trial court in this case was not the court that issued the ruling requiring this effort. That was the court of appeals. The trial court may be more willing to recognize the limitations other laws place on CMS and that HHAs do have a right to comment. (Which means CMS can't simply issue a new HHABN on July 1.) Of course, there is no way to know for sure until the Court rules.
The main point is that a new HHABN should be issued by in a few weeks, for now CMS continues to state it will abide the Paperwork Reduction Act and, as a result, the new HHABN deadline won?t be until early fall. In other words, for now July 1 is just a rumor.
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