Retrieved from Beacon Health

OASIS-C: About More Than Just Outcomes

Originally designed as a data set for measuring and managing outcomes, the OASIS has played a very important role in payment since 2000. Now, the Centers for Medicare and Medicaid Services (CMS) wants to include in the OASIS a way to measure an agency’s use of evidence-based best practices. The CMS believes that including best practices, which have been shown to prevent exacerbation of serious conditions, can improve care received by individual patients. The data can also provide guidance to agencies on how to improve care and avoid adverse events.

There are three types of best practice-related measures proposed for incorporation into the OASIS.

• Assessments/screenings:  Two questions, M1300, pressure ulcer assessment (risk), and M1910, fall risk assessment, ask whether the patient was evaluated for a particular problem.  A concern:  There is no option for noting that a formal assessment might not be necessary.  Answers are, “No assessment conducted,” “Yes, and it [indicates or found something],” and “Yes, and it [found nothing].”
  
  
• Plan of care interventions:  A complex table, M2250, plan of care synopsis, asks whether the “physician-ordered plan of care” includes parameters for physician notification, diabetic foot care, falls and pressure ulcer prevention, and interventions for pain, depression, and pressure ulcer treatment (moist wound healing).  Those process measures had been separate data elements in the previous version of OASIS-C.  This table is a slight improvement over the individual data elements; primarily because there is the option of noting interventions might not be necessary.
  
  
• Implementation of interventions:  Another complex table, M2400, intervention synopsis, asks whether the plan of care included the interventions identified in the preceding paragraph and whether these interventions were implemented.  There are several concerns about this data element.  The language is slightly different than that in M2250 and clinicians will need to read the data element carefully to ensure a correct answer.  The answer is either, “Yes” or “No.”  What would be the answer if the plan of care included interventions but they were not implemented or vice versa?
  
  

There are also questions on medication intervention, and patient and caregiver high-risk drug education.

More reasons to be concerned

The CMS, its advisors, and others working on the revised OASIS are excited about these changes; however, the staff at Beacon Health believe there are several issues of concern.

• The need for some of these processes is debatable. One example: parameters for physician notification. A clinician must notify a physician about changes that suggest a need to modify the plan of care, but there is no regulatory requirement for parameters. In many cases, they are not necessary.
  
  
• Many interventions, such as those to prevent falls or pressure ulcers, do not require physician orders and do not need to be on the plan of care.
  
  
• Because those interventions are preventive in nature, they would not be reasonable and necessary per Medicare’s coverage criteria.
  
  
• The time frames may not be realistic, such as one calendar day to notify the physician about medication issues.
  
  
• Some terms are not defined, e.g., significant medication issue or high-risk medication.
  
  

There are also some questions that need answers.

• Because the assessments and interventions are included in the OASIS, will it be mandatory for every agency to develop these?
  
  
• What level of detail will surveyors and intermediaries expect to see for these interventions?
  
  
• Will an agency have to defend itself every time an assessment is not completed or interventions are not implemented?
  
  
• What will be the repercussions if an agency is not successful in getting a physician to prescribe moisture-retentive dressings for a pressure ulcer or order follow-up measures when a depression screening identifies a concern?
  
  

There is little reason to debate that formal assessments and standardized interventions can be valuable. However, OASIS should not be the driving factor behind best practice initiatives—which will be the end result when a question asks whether something is planned and whether it was done. It is up to the agency to determine which best practices it will implement based on its patients and operations. Then OASIS can measure the results, the outcomes of care.

The comments in this article reflect one point of view—one that sees all the work necessary to establish and implement these best practices. The most important opinion, however, is that of your agency.

Now it’s your turn

To download the CMS’ most recent OASIS-C package, including supporting statement, and burden estimate, go to — http://www.cms.hhs.gov/PaperworkReductionActof1995/PRAL/list.asp#TopOfPage — and click on CMS-R-245.

To find the latest OASIS-C, click on - http://www.beaconhealth.org/pdfs/OASIS-C-MARCH-2009.pdf.

Study the information and then send in your comments by April 8 to:

OMB, Office of Information and Regulatory Affairs
Attention: CMS Desk Officer.
Fax Number: (202) 395–6974
E-mail: OIRA_submission@omb.eop.gov.

The Beacon Health seminar, “Mastering Medicare,” (next stop—Nashville on April 20 and 21) addresses OASIS-C and other important topics.  For more information, click on — http://www.beaconhealth.org/mastering_medicare/seminars09.html.

© 2009 Beacon Health. All Rights Reserved.