Posted by: Robert Markette
June 21, 2006

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.

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