OASIS and HHAs Seeking Initial Certification

2202.10 - OASIS and HHAs Seeking Initial Certification (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) Prior to receiving Medicare approval, HHAs must meet certain requirements, including enrollment and capitalization, and must provide skilled home health services to a minimum of 10 patients (not necessarily Medicare patients) that is consistent with the Medicare home health CoPs. This includes compliance with the OASIS collection and transmission requirements. New HHAs must demonstrate that they can transmit OASIS data prior to the initial certification survey. Specifically, new HHAs must apply for a user identification number and password from the State OASIS automation coordinator in order to register for an individual user identification and password which is used to electronically transmit to the OASIS System any encoded and locked SOC or ROC OASIS assessment record(s) for applicable Medicare and Medicaid patients in a test mode. HHA survey staff must communicate with the OASIS coordinators to determine this aspect of compliance prior to the initial onsite survey. SAs and AOs with deeming authority should not schedule initial surveys until the SA or AO has determined the HHA’s status with the OASIS transmission requirement. AOs may contact the state directly to determine the status of the new HHA’s activities concerning the OASIS transmission process prior to scheduling the onsite survey. The names and phone numbers of the State OASIS contacts are found on the OASIS Web site. To acquire an HHA personal login ID, agencies will be required to complete and submit the CMSNet Access Request form and the OASIS Individual User Account Request form. The forms are available on the QIES Technical Support Office website (https://www.qtso.com/). To meet the OASIS transmission requirements prior to the initial certification survey, new HHAs need two different sets of user identification numbers and passwords; one set to access the CMSnet and one set to access the OASIS System. The OASIS automation coordinator in each SA should assist the new HHA in obtaining the user identification numbers and passwords and guide HHAs through registration for an individual user identification and password prior to the initial certification survey. Once the communications software and access are in place, the new HHA must demonstrate that it can transmit OASIS data to the OASIS System by (1) making a test transmission of any SOC or ROC OASIS data that passes CMS edit checks; and (2) receiving validation reports back from the OASIS System confirming data transmission. Transmissions of test data prior to the OASIS System successfully uploading the certification kit in ASPEN will result in any submission file being processed as a test submission. The user will receive a final validation report showing any warning and fatal error messages associated with each record. However no data will be stored on the database until the initial certification kit has been successfully uploaded. Unless submitted as a test, once the certification kit is successfully uploaded all assessment data will be treated as live data and stored on the database. 2202.10A - Determining Compliance With the OASIS Transmission Requirements (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) Depending on the method of transmission the HHA chooses, the SA needs to determine compliance in one of the following ways: • If the new HHA chooses to independently transmit OASIS data from its own office, the State HHA survey team and OASIS coordinator must communicate with each other to establish that the new HHA has successfully transmitted test OASIS data using the appropriate user identification numbers and passwords, prior to onsite survey. The HHA should maintain all copies of validation reports for its records. • If the new HHA chooses to use a software vendor to meet the OASIS encoding and/or transmission requirement on its behalf, the HHA must still establish connectivity to the OASIS System via the software vendor. The HHA should have a written contract that describes this arrangement. The vendor and/or other certified HHA will need to apply for access to this agency as a Third Party Submitter. Forms are available on QTSO at: https://www.qtso.com/accesshha.html. • The HHA or its software vendor must apply for the applicable user identification numbers and passwords from the SA in order to establish connectivity with the OASIS System. As described above, the HHA survey team and OASIS coordinator must communicate with each other to establish that the software vendor, on behalf of the new HHA, has successfully transmitted test OASIS data using the appropriate user identification numbers and passwords, prior to onsite survey. The HHA should obtain copies of all validation reports from its software vendor for its records. • If the new HHA chooses to use another certified HHA to meet its transmission requirements, for example, another established HHA in the chain or other established but non-related HHA, the HHA must still demonstrate connectivity to the OASIS System via the other established certified HHA. The new HHA or other HHA must apply for user identification numbers and passwords, unique to the new agency, from the SA, in order to establish connectivity with the OASIS System. The new HHA must have clearly written policies outlining the procedures in place with the other HHA with regard to OASIS collection, encoding and submission to the OASIS State System and the sharing of feedback reports from the OASIS System with the new HHA. 2202.10B - HHAs Seeking Initial Certification Through Deemed Status (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) An HHA may choose to obtain initial Medicare certification by electing the deemed status option through an approved AO that has been granted deeming authority for Medicare requirements for HHAs. There are currently three AOs with deeming authority for HHAs - the Joint Commission (TJC), the Community Health Accreditation Program (CHAP), and the Accreditation Commission for Health Care, Inc. HHAs seeking initial certification through the deemed status option must still apply to the SA for user identification numbers and register as an individual in order to demonstrate compliance with OASIS submission requirements prior to approval. When the SA receives a request from an HHA interested in seeking Medicare deemed status through accreditation by an AO with deeming authority, the State ensures that the HHA understands its obligation to meet the OASIS requirements, even when the AO conducts the initial certification survey. This includes compliance with the OASIS collection and transmission requirements. If the SA receives a certification packet from an HHA seeking Medicare certification based on its accreditation through a deemed status program, it is the SA’s responsibility to determine that the HHA meets its OASIS transmission responsibilities. The OASIS transmission responsibility may be met in one of the three ways described above. 2202.10C - Exceptions to Demonstrating Compliance With OASIS Submission Requirements Prior to Approval (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) New HHAs that intend to admit or treat only patients to whom OASIS currently does not apply, i.e., patients under 18, maternity, and patients receiving only unskilled care or chore services are not expected to demonstrate compliance with OASIS submission requirements prior to approval. These HHAs must attest this intention to the SA. After certification, if there is a change in the HHA’s policies that includes the acceptance of patients to whom OASIS applies, the HHA is expected to install the necessary communications software and contact the SA and CMSnet for the applicable user identification numbers and passwords. 2202.10D - Compliance Dates and PPS (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) Compliance with the rest of the CoPs is determined via an onsite survey by the SA and any applicable subsequent actions or revisions required of the HHA following the initial survey. After survey, the new HHA cannot bill Medicare for payment of services to Medicare beneficiaries until the effective date for Medicare participation has been determined by the CMS RO. Realistically, notification of the effective date may come many weeks after the initial survey of the HHA. In addition, the date of official compliance may vary depending on the outcome of the onsite survey. As described in §2780, the date of compliance is either: 1. The date the onsite survey is completed if, on the date of the survey the HHA meets all CoPs and any other requirements required by CMS; or 2. If the HHA fails to meet any of the requirements as a result of the onsite survey, compliance is the earlier of: • The date the HHA meets all enrollment requirements; or • The date the HHA meets all the CoPs and submits an acceptable plan of correction for standard level deficiencies. Payment under Medicare for services provided prior to the effective date for Medicare participation is not permitted. As such, it is important that new HHAs seeking payment under Medicare establish the required 60-day episode on or after the effective date of their Medicare participation. 2202.10E - Instructions for Handling Medicare Patients in HHAs Seeking Initial Certification (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) The Medicare OASIS submission and billing process cannot begin until the effective date of the HHA’s CCN, which is assigned after the RO has done the review of the initial survey findings, plan of correction if one was necessary, documentation on whether the HHA has met the enrollment requirements, and documentation that the MAC has completed the second capitalization review. Enrollment requirements include completion of the CMS Form 855A, first capitalization review, completion of a survey by a SA or RO with the HHA in compliance with the CoPs, additional development by the MAC and second capitalization review by the MAC. After it is assigned its CMS certification number (CCN) by the RO, the HHA should do a new SOC assessment (RFA 1) on each of its Medicare eligible patients. This assessment visit date should be consistent with the first billable visit date after Medicare participation becomes effective. Once the CCN has been assigned, the HHA can go back and encode the collected OASIS information, obtain the necessary payment system codes for billing under PPS, and transmit the information to the OASIS State System as production (i.e., “live”) data. The date of this assessment will become day 1 of the HHA’s first 60-day episode under Medicare, as long as the assessment was done in conjunction with a billable visit. Warning messages related to noncompliance with timing requirements are unavoidable and are to be expected in this situation. If compliance (i.e., the effective date) is not the date of the onsite survey, it will be based on D.2. above, as further outlined in §2780. The HHA should, again, do a new SOC assessment (RFA 1) on each of its Medicare patients at the first billable visit after the anticipated date of compliance, delay encoding and transmitting the assessment until the CCN is assigned, and continue as outlined in the paragraph above. That is, the HHA should go back and encode the collected OASIS information, obtain the necessary payment codes for billing under PPS, and transmit the information to the OASIS State System as production data. As above, warning messages related to noncompliance with timing requirements are unavoidable and are to be expected in this situation. If the new HHA did not conduct a SOC (RFA 1), ROC (RFA 3), or Follow-up (RFA 4) OASIS assessment during the time between the effective date for Medicare participation and the date the HHA learns of its approval, the HHA should conduct a SOC assessment, as soon as possible. This assessment can be used to generate the payment code used for billing under Medicare. The SOC date should reflect a date that is consistent with the first billable visit after the effective date for Medicare participation, as stated above. 2202.10F - Instructions to New HHAs Concerning all Other Patients (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) Non-Medicare and Non-Medicaid patients do not require OASIS collection or transmission. For all other patients treated by the HHA (i.e., non-Medicare or non-Medicaid patients), if a new start of care date is not required by the patient’s payer source, the HHA should encode and transmit all OASIS assessments as required by current regulation that were collected after the effective date of Medicare participation. These assessments should be submitted in the production mode using the newly assigned provider number. The HHA should continue with the OASIS assessment schedule already established based on the patient’s admission date.