Surveying for the OASIS Requirements

2202.8 - Surveying for the OASIS Requirements (Rev. 1, 05-21-04) The comprehensive assessment regulation requires that HHAs use a standard core data set, i.e., OASIS, when evaluating adult, non-maternity Medicare and Medicaid patients (except those receiving exclusively homemaker or chore services.) The OASIS meets the condition specified in §1891(d) of the Act, which requires the Secretary to designate an assessment instrument in order to evaluate the extent to which the quality and scope of services furnished by the HHA attained and maintained the highest practicable functional capacity of the patient as reflected in the plan of care. These regulatory changes are an integral part of CMS’ efforts to achieve broad-based improvements in the quality of care furnished through Federal programs and in the measurement of that care. Since the requirement to report OASIS data to the OASIS State System is not part of the standard survey process, while determining compliance with the comprehensive assessment of patients is, both offsite and onsite monitoring are required to determine compliance with the OASIS CoPs. The State OASIS Educational and Automation Coordinators can assist with the offsite monitoring for OASIS compliance and in providing available OASIS reports, (e.g., data management, quality monitoring and quality improvement reports) to surveyors. HHAs that do not collect and report accurate and complete OASIS data for all applicable HHA patients risk citations at the standard and condition levels. HHAs found not to be in compliance may be subject to enforcement actions and/or termination from the Medicare program. 2202.8A - Condition of Participation: Comprehensive Assessment of Patients (See §484.55) (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) This CoP states that a comprehensive assessment of the patient, in which patient needs are identified, is a crucial step in the establishment of a plan of care. In addition, a comprehensive assessment identifies patient progress toward desired outcomes or goals of the care plan. HHAs complete the OASIS items as part of the clinician’s total assessment process. This process is not based solely on interviewing the patient. Conducting a patient’s comprehensive assessment involves both observation and interview. These data collection techniques complement each other. Many HHA clinicians begin the assessment process with an interview by sequencing questions to build rapport and trust. Others choose to begin the assessment process with a familiar procedure such as taking vital signs in order to demonstrate clinical competence to the patient before proceeding to the interview. HHAs are expected to complete all OASIS items as accurately as possible while minimizing burden and intrusion on the patient. HHAs should not force patients to cooperate with the assessment process; rather, they must do the best they can to assess patients who do not fully cooperate with the assessment process. Since collecting OASIS information rarely depends solely on patient interview, HHAs are expected to complete, encode, and transmit all OASIS data items. If patients refuse to answer some questions that are part of the OASIS assessment, HHAs may still deliver care to the patient as long as they complete and submit the OASIS assessment to the best of their ability. States may advise HHAs that seem to report difficulty with specific OASIS items to review the processes of performing a comprehensive assessment with their staff. Sometimes such difficulties indicate that staff might benefit from additional training or retraining in assessment skills. The OASIS Web-based Training Internet site provides additional guidance on “OASIS and the Comprehensive Assessment” and “How to effectively conduct a comprehensive assessment” for clinicians who are challenged by these activities. As stated in the CoPs, each patient (except those under 18; receiving maternity services; receiving only services such as homemaker or chore services; or, until sometime in the future, receive personal care services only), regardless of payer source, is expected to receive from the HHA a comprehensive assessment that accurately reflects the patient’s current health status and incorporates the exact language of the OASIS data items required for the time points specified in this condition. The requirement to collect OASIS data as part of the comprehensive assessment for non- Medicare /non-Medicaid patients is temporarily suspended, effective December 8, 2003, as a provision of the Medicare Prescription Drug, Improvement and Modernization Act of 2003. HHAs must continue to comply with the aspects of the regulation at §484.55 regarding the comprehensive assessment of patients. HHAs must provide each agency patient, regardless of payment source, with a patient-specific comprehensive assessment that accurately reflects the patient’s current health status and includes information that may be used to demonstrate the patient’s progress toward the achievement of desired outcomes. The comprehensive assessment must also identify the patient’s continuing need for home care, medical, nursing, rehabilitative, social, and discharge planning needs. • HHAs may continue to collect OASIS data on their non-Medicare/non-Medicaid patients for their own use. • Surveyors must continue to examine the completeness of the comprehensive assessment for all patients during a survey. However, surveyors must not investigate whether the HHA included the specific OASIS items in its patient- specific comprehensive assessments of non-Medicare/non-Medicaid patients, nor cite deficiencies based solely on this finding. The CoP is comprised of the following five standards. 1. Initial Assessment Visit This standard requires that an initial visit be performed to determine the immediate care and support needs of the patient. The initial assessment visit requirement is intended to confirm beneficiary eligibility, to ensure that the patient’s most critical needs for home care services are identified and met in a timely fashion, and to perform the skilled care that was ordered. It is not required that a SOC comprehensive assessment be completed at this visit, although the HHA may choose to do so. If the HHA does not complete the SOC comprehensive assessment during the initial visit, then the comprehensive assessment must be completed and updated according to the required time points. • The initial assessment visit is conducted by a registered nurse and must occur either within 48 hours of referral or within 48 hours of the patient’s return home from a hospital stay of 24 hours or more for any reason other than diagnostic testing, or on the SOC date ordered by the physician. • For Medicare patients, the initial assessment visit must include a determination of the patient’s eligibility for the home health benefit. Verification of a patient’s eligibility for the Medicare home health benefit including homebound status does not apply to Medicaid patients, beneficiaries receiving Medicare outpatient services, or private pay patients. • When rehabilitation therapy (speech-language pathology, physical therapy, or occupational therapy) is the only service ordered by the physician, and if the need for that service establishes program eligibility, the initial assessment visit may be made by the appropriate rehabilitation professional. For the purpose of the initial visit, a therapy case that includes knowledge of skilled nursing for a one-time visit to remove sutures or draw blood is not considered a therapy-only case. The initial visit must be conducted by the qualified registered nurse. NOTE: While Medicare pays for occupational therapy, eligibility for the Medicare home health benefit cannot be established based solely on the need for that service. The need for occupational therapy does not establish eligibility for the Medicare home health benefit. However, the Medicare home health patient with multiple service needs can retain eligibility if, over time, the only remaining need is for occupational therapy. Therefore, under the Medicare benefit, the Occupational Therapist (OT) cannot conduct the initial assessment. An OT can conduct the Follow-Up assessment and those associated with transfers and discharges. Occupational therapy, could, however, establish eligibility, in some States, under the Medicaid program. In the case of Medicaid patients (or Medicare patients receiving therapy services), if the need for a single therapy service either establishes eligibility or allows eligibility to continue once it is otherwise established, the corresponding practitioner, (including a PT, SLP, or OT) can conduct any of the designated assessments. 2. Completion of the Comprehensive Assessment • When a patient is first admitted to the HHA, a comprehensive assessment must be completed no later than 5 calendar days after the SOC date. The comprehensive assessment for all Medicare and Medicaid patients receiving skilled services must include OASIS data. OASIS data is not required for non-Medicare/non-Medicaid patients at this time. However, HHAs may include OASIS data if they choose. Additional comprehensive assessments are required throughout a patient’s course of treatment. • A registered nurse must complete the comprehensive assessment and, for Medicare patients, confirm eligibility for the Medicare home health benefit. • When physical therapy or speech-language pathology is the only service ordered by the physician, the PT or SLP may complete the comprehensive assessment. For the purpose of the SOC comprehensive assessment, a therapy case that includes skilled nursing for a one-time visit to remove sutures is not considered a therapy- only case. The SOC assessment in this case should be conducted by the qualified registered nurse but may be completed by the qualified therapist at subsequent time points. The same discipline is not required to complete the subsequent assessments at every required time point. The HHA can decide how best to approach the assessment process at the required time points. For other than Medicare, OTs may complete the SOC assessment when the need for occupational therapy establishes program eligibility. (See NOTE above concerning eligibility for the home health benefit and occupational therapy services.) • The SOC comprehensive assessment may be completed in more than one visit as long as it is completed within the 5-day time frame required by the regulations. • Non-clinical staff, i.e., those not qualified by current regulation, may not assess patients or complete assessment items; however, non-clinical staff or data entry operators may enter the OASIS data collected by the qualified skilled professional into the computer. Many elements in the Clinical Records Items section (which identifies the patient) of each OASIS data set may be completed initially by clerical staff as part of the intake/referral process; but should be verified by the qualified clinician doing the assessment. Master of Social Work Only Evaluations Visits for medical social work assistance only are frequently requested by case managers. A visit for medical social work in order to evaluate the patient’s need or eligibility for community services generally is not considered a visit to conduct a comprehensive assessment of the patient and would not solely qualify a patient for Medicare home care eligibility. If a physical assessment of the patient is conducted, as is required by the comprehensive assessment regulations, it must be done by a qualified person. In this case, that qualified person must be an RN, PT, SLP or OT (as applicable). Drug Regimen Review The drug regimen review requirement was moved from the previous plan of care requirements to the new comprehensive assessment requirement to reflect the true nature and purpose of this activity. The comprehensive assessment must include a review of all medications the patient is currently using in order to determine compliance with drug therapy, significant side effects and drug interactions, potential adverse effects and drug interactions, ineffective drug therapy, and duplicate drug therapy. The previous requirements for drug regimen review were modified by eliminating the actual identification of “adverse actions” and “contraindicated medications” and substituting the requirement to review drug therapy compliance, drug interactions, and duplicative drug therapy. 3. Update of the Comprehensive Assessment In order to have data that is comparable across HHAs, OASIS data must be collected at uniformly defined time points including recertification. This requirement is not expected to add to the number of skilled visits provided by the HHA. Many HHAs arrange visit schedules to accommodate home health aide supervisory requirements and patient and care giver schedules. HHAs are expected to similarly adjust the patient’s visit schedule in order to accommodate OASIS time points. OASIS reassessment visits that are not part of a treatment visit are overhead/administrative costs and not separately billable visits. They do not require a physician order. The comprehensive assessment, which includes the OASIS data items for Medicare and Medicaid patients, should be updated and revised no less frequently than: • During the last 5 calendar days of the current 60-day certification period beginning with the SOC date (Follow-up OASIS data set); or within 48 hours of (or knowledge of) the patient’s return home from a hospital stay of 24 hours or more for any reason except diagnostic tests (ROC OASIS data set). If these two assessment time periods fall within the five day window, only the ROC assessment must be completed; • Within 48 hours of (or knowledge of) transfer to an inpatient facility (Transfer to an Inpatient Facility OASIS data set, with or without agency discharge); • Within 48 hours of (or knowledge of) the patient’s return home from an inpatient stay other than a hospital. (See major decline or improvement in the patient’s health at 4. below;) • Within 48 hours of (or knowledge of) discharge to the community or death at home (Discharge OASIS data set); and • For non-Medicare/non-Medicaid patients, HHAs must provide each agency patient with a patient-specific comprehensive assessment at the above time points to accurately reflect the patient’s current health status and the patient’s progress toward achievement of desired outcomes. In a case involving more than one discipline, the SOC assessment should be conducted by the qualified registered nurse but may be conducted by the qualified therapist at subsequent time points. The same discipline is not required to complete the subsequent assessments at every required time point. The comprehensive assessment updates should include the appropriate OASIS items as indicated on the data set for the respective time points, (i.e., SOC, ROC, Follow-Up, transfer to inpatient facility with or without discharge, discharge, and death at home). If home health care is resumed after an inpatient stay, the comprehensive assessment must include the OASIS items appropriate for assessment after an inpatient stay. If the patient is not formally discharged at the time of transfer to an inpatient facility, the agency completes a comprehensive assessment that includes the ROC OASIS data items. If the patient is formally discharged from the HHA, the data collection proceeds on the basis of a new agency SOC date that follows the inpatient stay; therefore, a SOC comprehensive assessment is conducted. The ROC and SOC (minus the Patient Tracking Sheet) OASIS data sets are actually the same data set. For purposes of OASIS data collection, the HHA can establish its own internal policies regarding criteria for formal discharge versus interrupting home care services but maintaining the patient on the HHA admission roster, i.e., placing the patient on “hold” status. (See OASIS and the Home Health Prospective Payment System for exceptions to this general rule.) If the patient is under the care of the HHA and is not formally discharged prior to the end of the current 60-day period, the HHA conducts the next comprehensive assessment during the last 5 days of the current 60-day period beginning with the original SOC date. For example, if the SOC date were June 25, 2014, the patient would be reassessed between August 18 and August 22, 2014. If the HHA transfers a patient to an inpatient facility and places the patient on “hold” status, no further assessments are conducted and no data is collected while the patient is in the inpatient facility. The HHA is not providing care while the patient is on “hold” during the inpatient stay. At the time the patient is transferred to the inpatient facility, a transfer assessment (response 6 selected for M0100) is completed. When the patient returns to home care, the HHA completes the ROC assessment (response 3 selected for M0100). (See OASIS and Home Health Prospective Payment System for exceptions to this general rule.) The ROC assessment is required within 48 hours of the patient’s return home from the inpatient facility unless otherwise determined by physician’s orders. The Follow-up assessment is required during the last 5 days of the current 60-day (recertification) period. It is possible for these two time periods to overlap. If they do, M0100, ROC (response 3), should be marked. If these two periods DO NOT overlap, two comprehensive assessments should be completed in accordance with the regulations. One assessment is done for the ROC while the other is done for the follow-up time point. (See OASIS and Home Health Prospective Payment System for exceptions to this general rule.) 4. Major Decline or Improvement in the Patient’s Health Status The OASIS regulations require that assessments with OASIS data collection be performed at certain time points. In the event an HHA determines that a patient’s condition has improved or deteriorated significantly at a point in the episode of care that is not already captured at a required time point, the HHA should collect and report additional assessment information. Each HHA should define major declines or improvements in the patient’s health status. Thus, the term “major decline or improvement in the patient’s health status” is the impetus for collecting and reporting OASIS data to: • Assess a patient on return from an inpatient facility other than a hospital, if the patient was not discharged upon transfer (ROC OASIS data set); and • As defined by the HHA (Other Follow-up OASIS data set). 5. Incorporation of OASIS Data Items Integrating the OASIS items into the HHA’s own assessment system in the order presented on the OASIS data set facilitates data entry of the items into the data collection and reporting software. Agencies may integrate the items in such a way that best suits their assessment system. Some agencies may wish to electronically collect their OASIS data and upload it for transmission to the State. As long as the HHA can format an output file for transmission to the State (that is, in the 1448-byte data string format specified by CMS), it doesn’t matter in what order it is collected; however, this is not recommended because of the skip patterns that are built into the OASIS data set. In accordance with the regulations, data MUST be transmitted in the sequence presented on the OASIS data set. The HAVEN software will prompt HHAs to enter data in a format that will correctly sequence it and ultimately be acceptable for transmission. HHAs collecting data in hard copy or electronic form must incorporate the OASIS data items into their own assessment instrument using the exact language of the items. Agencies are expected to replace similar items/questions on their existing assessment tool as opposed to simply adding the OASIS items at the end. For agencies using software that does not accommodate bolding or underlining for emphasis of words in the same manner as the current OASIS data set, software that capitalizes these words is acceptable, including the M numbers when integrating is also recommended. In this way, the HHA will know that the M labeled items are items that MUST be assessed and completed. This will minimize delays in encoding due to incomplete OASIS data items. HHAs may wish to incorporate the assessment categories (e.g., ADLs/IADLs, Medications, etc.) into their own assessment instrument in a different order than what is presented on the OASIS data set; however, as stated above, the agency must consider any skip instructions contained within the questions in the assessment categories and provide the proper instructions. 2202.8B - Record Keeping (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) Since the OASIS data set is incorporated into the HHA’s comprehensive assessment, the clinical record must be maintained according to existing CoPs for clinical records. Records of both active and discharged patients must be readily retrievable for use by SA staff. Surveyors may need to ask for orientation to the HHA Electronic Health Record, as providers have the right to use whatever system of medical records they choose. Surveyors will cooperate and work with facilities that use Electronic Health Records. During the entrance conference, surveyors will establish with the agency the process they will follow in order to have unrestricted access to the medical record. Electronic access to records will not eliminate the need for a surveyor to print a paper copy or to request a paper copy of certain parts of a record. However, the surveyor shall make reasonable efforts to avoid, where possible, the printing of entire records. The surveyor should print or request a paper copy of only those parts of records that are needed to support findings of noncompliance, unless protocols for particular types of surveys require otherwise. Although not required, it is recommended that the HHA print hard copies of the electronic validation records received from CASPER and store the validation records in an electronic format for twelve months, until the next set of OBQI reports are available. The validation reports may be needed as evidence if the HHA receives a denial from the MAC for missing OASIS assessments. The OASIS Activity Report in CASPER provides a list of assessments that were submitted and accepted by a HHA in the previous calendar month. Information provided in these activity reports includes Patient ID, SSN, Patient Name, RFA, Effective Date and Submission Date. This report is generated automatically on the 5th of each month. Rejected records are not reported within the Activity Report as the patient information is not stored for rejected records. The activity reports can be found with the validation reports under the naming convention of ARmmyyyy.txt. For example reports completed with data submitted and accepted in the month of September 2010 will display as AR092010.txt. Note: The Activity Reports are deleted from the state servers on the same cycle as the validation reports, therefore it is essential to either save the reports to a secured network as a text file OR print and save the report. 2202.8C - Condition of Participation: Reporting OASIS Information (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) Except as specified in the June 18, 1999 notice, HHAs must report OASIS data on all patients (except those under 18, those receiving maternity services, and those receiving housekeeping or chore services only) in a format that meets CMS specifications. HHAs or contracted entities acting on behalf of the HHA can report OASIS data to the SA using the HAVEN software CMS provides or by using HAVEN-like software that conforms to the same specifications used to develop HAVEN. Once reported to a CMS central database, the compiled, aggregate OASIS data (i.e., outcome reports) can be used by the HHA to determine how it is performing in terms of patient outcomes compared with other HHAs. 1. Encoding OASIS Data HHAs must encode (that is, enter OASIS data into a computer using HAVEN or HAVEN-like software) and finalize (make export ready) data entry for all applicable patients in the agency within 30 days of the M0090 date of an OASIS data set. Once the OASIS data set has been collected at the specified time points described above, HHAs may take up to 30 calendar days after the M0090 date of collection to enter the assessment into their computer systems. For example, if the comprehensive assessment is completed on May 1, the data must be encoded by May 31. (HHAs should consider implementing a tracking system that considers the window for correcting OASIS assessments that need corrections before submission.) HHAs will enter their OASIS data into their computers using HAVEN or HAVEN-like software. HAVEN will automatically review the data for accuracy and consistency; it will alert the HHA to make any necessary changes in order to finalize or lock the data. The locking mechanism is necessary to ensure the accuracy of the patient assessment at the point in time that the assessment took place. The locking mechanism will prevent the override of current assessment information with future information. HHAs will be prompted by HAVEN to export and store encoded data into an electronic file. The export file is transmitted to the State by the HHA. 2. Accuracy of Encoded OASIS Data Encoded OASIS data must accurately reflect the patient’s status at the time the information was collected. In preparation for transmission to the State, the HHA should ensure that data encoded into the computer is identical to the OASIS data items completed by the skilled professional. HHAs should, therefore, develop systems to ensure that encoded data matches the OASIS data items completed by the skilled professional. Such a monitoring system could include staff appointed to audit sample OASIS records after data is encoded as part of the agency’s overall quality assurance program. 3. Transmission of OASIS Data After being exported to a transmission-ready file, the export ready data should be transmitted to the State or CMS contractor. HHAs transmit OASIS data at least monthly. By the last day of each month, HHAs should electronically transmit all OASIS data made export ready during the previous month for each patient (as applicable based on M0090 date) to the SA. NOTE: CMS requires the encoding and transmission of OASIS information only on patients who are receiving Medicare/Medicaid benefits. This means that for patients with payer source (1) Medicare (traditional fee-for-service), (2) Medicare (HMO/Managed Care), (3) Medicaid (traditional fee-for-service), or (4) Medicaid (HMO/Managed Care) on OASIS item M0150, the HHA must collect, encode and transmit all required OASIS information to the SA. If Medicare/Medicaid is contributing to the payment of the patient’s episode of care, the patient is considered a Medicare/Medicaid patient. The payer source for services provided as part of a Medicaid waiver or home and community-based waiver program by a Medicare-approved HHA are coded as (3) Medicaid (traditional fee-for-service) at item M0150. For non-Medicare/non-Medicaid patients (patients with only pay sources other than M0150 response 1, 2, 3, or 4, the HHA is not required to assess and collect OASIS as part of the comprehensive assessment and agency medical record. Alternatively, the HHA must use its own comprehensive assessment as the requirement to collect OASIS data is temporarily suspended. Non-Medicare/non- Medicaid payer sources include private insurance, private HMO/Managed Care, self pay, programs funded under the Act: for example, Title III, V, XX, or other Government programs. HHAs must have a computer system that supports transmission of OASIS data via the CMSnet to the SA (or other designated location), transmits the export file, and receives validation information. CMS provides HHAs access to the CMSnet, a private communications network CMS purchased to ensure the security of OASIS data transmissions to the State. Use of the CMSnet allows for all data submitted to the OASIS State System to be encrypted during the transmission process precluding any unauthorized sources from intercepting identifiable data. Similarly, data reports, which are sent by the OASIS State System to the HHA across the CMSnet are also automatically encrypted and decoded. This network encryption occurs automatically when the HHA uses the CMSnet and requires no special action on the part of the HHA other than using browser software that supports industry standard encryption. 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. User identifications and Passwords to access the OASIS State System to submit assessments or obtain CASPER reports are now specific to individuals(2) and should not be shared. The CMSnet is how HHAs transmit their OASIS data. HHAs must install the communications software, which is separate from the HAVEN software, which will allow them to access the CMSnet. 1.) The supported version of the dialer/CMS vendor is posted on the CMSNet page on https://www.qtso.com/mdcn.html. The helpdesk that supports the CMS vendor is the CMSnet Help Desk. Their phone number is: 1-800-905-2069 Opt 2. In the event that CMS changes telecommunication vendors, updates to requirements will be made known on the All State Technical Call and on the QTSO website. 2.) Instructions for downloading and installing this software are available on the OASIS Web site. Alternatively, HHAs can call the HAVEN help desk at 1-877- 201-4721 for help in obtaining and installing this software. When the OASIS System receives a transmission file, it validates the reported information while the HHA remains on-line to ensure that some basic elements conform to CMS requirements, such as proper format and HHA information. Once these file checks are complete, a message indicating whether the file has been accepted or rejected is automatically sent back to the HHA’s computer via the agency’s communication link. If the submission is rejected, an informative message is sent to the HHA. A file may be rejected for a variety of reasons. For example, the HHA Facility ID in the header record may be incorrect and not match the Facility ID at the State, or the number of records indicated in the trailer record is different from the actual number of records submitted. The HHA needs to make the corrections and re- submit the file to the State. If the submission passes the initial validation check, the file is checked further for errors or exceptions to the data specifications and a Final Validation Report is generated up to 48 hours later. 4. Data Format The format used for encoding and transmitting OASIS data should conform with software available from CMS or other software that conforms to the CMS standard layout, edit specifications, and data dictionary including the OASIS data set. Details regarding these specifications are available on the OASIS Web site. The software must also include the most current version of the OASIS data items which will be available on the OASIS Web site at all times. CMS provides registered HAVEN users with instructions for any revised HAVEN software. HAVEN will prompt the user to enter the data items associated with a required time point by providing the user with the correct screens for the specific type of assessment data required. HHAs will be able to use HAVEN to encode OASIS data, maintain agency and patient-specific OASIS information, and create export files to submit OASIS data to the OASIS System. HAVEN provides comprehensive on-line help for encoding, editing, and transmitting these data sets. Additionally, the HAVEN help line (1-877-201-4721) is available to HHAs with questions concerning the installation and use of HAVEN. The export function in HAVEN produces an ASCII text file from the HAVEN database. The file meets the OASIS data specifications that must be transmitted to the system. The OASIS System will reject all assessments with a non- Medicare/non-Medicaid payment source; therefore HAVEN will not include these assessments in the export file. The following chart summarizes the required time points and time frames outlined in the regulations for collection, encoding, and reporting OASIS data. OASIS ASSESSMENT REFERENCE SHEET RFA = Reason For Assessment RFA Type RFA Description Assessment Completed Locked Date Submission Timing 01 SOC - further visits planned Within 5 calendar days following the SOC Date (M0030) Effective 6/21/2006 No required lock date Effective 6/21/2006 Transmission required within 30 calendar days of completing the assessment (M0090) 02 SOC - no further visits planned Within 5 calendar days following the SOC Date (M0030) 03 ROC - after inpatient stay Within 2 calendar days following the ROC Date (M0032) 04 Recertification - Follow-up Completed (M0090) every 60 days following SOC: no earlier than day 56 and no later than the day (day 60) on which the certification period ends 05 Other Follow-up Complete assessment (M0090) within 2 calendar days following identification of significant change of patient’s condition RFA Type RFA Description Assessment Completed Locked Date Submission Timing 06 Transferred to inpatient facility - not discharged from agency Within 2 calendar days following or knowledge of disch/trans/death date (M0906) 07 Transferred to inpatient facility - discharged from agency Within 2 calendar days following or knowledge of disch/trans/death date (M0906) 08 Died at home Within 2 calendar days following or knowledge of disch/trans/death date (M0906) 09 Discharged from agency: Not to inpatient facility Within 2 calendar days following or knowledge of disch/trans/death date (M0906) 2202.8D - Condition of Participation: Release of Patient Identifiable OASIS Information (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) This CoP states that an agent acting on behalf of the agency, in accordance with a written contract, must ensure the confidentiality of all patient identifiable information contained in the clinical record, and may not release it to the public. The purpose of this provision is to ensure that access to all OASIS data (hard copy as well as electronic data) is secured and controlled by the HHA. This requirement mandates that the HHA ensures the confidentiality of all patient identifiable OASIS information contained in the clinical record and may not release it for any reason other than for what it is intended, which is to transmit to the SA for the development of outcome reports. The HHA’s policies should include assignment and maintenance of secure passwords required for encoding and transmitting OASIS data. Policies should narrowly define the qualifications of individuals having access to the OASIS software. For security reasons, passwords are required in the HHA for access to the agency’s computer system. A separate password is required for transmitting the OASIS data files to the SA. Privacy and confidentiality of OASIS data are extremely important. Coverage under the Federal Privacy Act of 1974 begins when the data reaches the SA. The Privacy Act protects OASIS data from unauthorized use and disclosure and has been effective in ensuring confidentiality of Medicare data. HHAs may choose to encode and transmit OASIS data to the SA themselves, or may contract with an outside entity (agent) to fulfill these requirements. Agents acting on behalf of the HHA, such as a data entry and submission vendor or contractor, guided by a written contract, are bound by the same confidentiality rules. The HHA is ultimately responsible for compliance with the confidentiality requirements and is the responsible party if the contractor does not meet the requirements. HHAs using HAVEN are prompted to enter agent information during set up of the HAVEN program. Data in the hands of an entity contracted by the HHA for data transmission is not covered by the protections of the Privacy Act, therefore policies related to the security of the OASIS data set are required. HHAs contracting with outside entities for data submission are ultimately responsible for the confidentiality and use of that data. Agreements between HHAs and their contractors should specify that the data is only to be used for its intended purpose, that is, to create outcome reports. As such, identifiable data must be treated in accordance with State law and must not be disclosed without patient consent. Violations of data confidentiality by an entity contracted by the HHA are the responsibility of the HHA and would constitute condition-level non-compliance. Agents must be aware of the requirements and security policies of the HHA and the SA concerning passwords, as well as the requirements of the OASIS System of Records and the Privacy Act.