Information Bulletin 99-9
Outcome and Assessment Information Set (OASIS) Update
This Information Bulletin addresses the delay in conducting a comprehensive assessment utilizing the Outcome and Assessment Information Set (OASIS) and transmission of the OASIS data to the State Agency. This bulletin supersedes Information Bulletin 99- 4.
Delay in Mandatory Collection and Use
On January 25, 1999, HCFA published a regulation (HCFA-3007-F, 64 FR 3764) requiring all home health agencies (HHAs) participating in the Medicare/Medicaid program to use a standardized assessment instrument, Outcome and Assessment Information Set (OASIS), for all patients. In order for this mandate to be valid, HCFA needs to obtain appropriate clearances under the Paperwork Reduction Act. The completion of this activity has been delayed, thus delaying the requirement that HHAs must use the OASIS data set as part of their comprehensive assessment process. Upon obtaining the appropriate clearances, HCFA will issue a notification on the HCFA Internet site (CMS.gov) and publish a notice to this effect in the Federal Register.
In the meantime, HCFA is not requiring HHAs to use the OASIS instrument nor are they requiring that comprehensive assessments be conducted at the specified time frames. HHAs that were not meeting the requirements on or after the February 24, 1999, effective date will not be held out of compliance.
However, during this period of delay, HHAs may wish to continue to use the OASIS instrument as part of their assessment tool, as it was developed to be useful in assessing and improving the care that HHAs furnish. This is a decision each agency will need to decide.
Delay in Mandatory Encoding and Transmission of OASIS Data
On January 25, 1999, HCFA published an interim final regulation (HCFA-3006-IFC, 64 FR 3748) mandating that all HHAs participating in the Medicare/Medicaid program encode (that is, data enter) OASIS information in a standard format and transmit it to HCFA as a condition of participation. In order for this mandate to be valid, HCFA needs to obtain appropriate clearances under the Paperwork Reduction Act, prepare and provide an individual Privacy Act notice for patients, and publish a Privacy Act notice of the existence and character of the OASIS system of records. The completion of these activities has been delayed, thus delaying the requirement that HHAs encode and transmit OASIS data. Upon obtaining the appropriate clearances and notices, HCFA will issue a notification on the HCFA Internet site (CMS.gov) and publish a notice to this effect in the Federal Register.
In the meantime, HCFA is not requiring HHAs to encode and transmit OASIS data. HHAs that were not meeting the encoding and transmission requirements on or after the March 26, 1999 effective date will not be held out of compliance.
When the appropriate clearances and notices are obtained, the collection, encoding and transmission of the OASIS data may again become effective. The new effective date will be determined by the date of the publication. There will not be retroactive expectations in relation to collecting, encoding and transmission of the data.
There may be a further delay in the transmission of data for private pay patients. What this means is that when OASIS becomes effective again after the appropriate clearances and notices are obtained, HHAs may be required to collect the data on their private pay patients, but not transmit until a later date. HCFA is still having discussions related to this. The new release of the state agency software, which was effective as of April 30, 1999, does not allow for the State OASIS system to accept assessments on private pay patients. What this means is that if a HHA were to encode and transmit a private pay patient record to the State Agency system, the agency would receive a fatal record error and this will result in the rejection of the individual record.
HHAs may continue to send "test" transmissions of records as the state system will continue to accept this information. The state supported OASIS Help Desk will also continue to be operational to answer your questions from staff. The phone numbers are (651) 201-3818 in the Twin Cities metro dialing area, and 1-800-657-3879 in other areas of the state. Please continue to monitor the HCFA OASIS website for further updates at: CMS OASIS
To obtain a copy of this Bulletin and the Federal Register notice that was published May 4, 1999, please contact:
Minnesota Department of Health
Health Regulation Division
85 East Seventh Place, Suite 300
St. Paul, Minnesota 55101
Telephone: (651) 201-4301