by Trisha Tulloch, RN, BSN, MSN, HCS-D

TRISH TULLOCH

TRISH TULLOCH

With less than three months until OASIS changes again, home health providers are proactively organizing and finalizing OASIS-C training initiatives to provide up-to-date information on critical new and revised assessment items based on the Centers for Medicare and Medicaid Services (CMS) Guidance. Additionally, agency leadership is assessing the impact of these changes to OASIS and revising agency processes to accommodate those requirements.

This article explains the leadership considerations that can have the biggest impact on home health providers and the decisions that need to be finalized to assure that OASIS-C staff training will enhance clinical practice consistency.

LEADERSHIP CONSIDERATIONS

Best Practices – Optional or Required?
Agency clinical leadership should first take the time necessary to compare the agency’s current comprehensive assessment format and content, which includes OASIS-B1, with the revised OASIS-C elements. CMS has created a helpful crosswalk that can form the foundation of the review. It can be found at http://www.cms.hhs.gov/OASIS/Downloads/OASISC3ColumnChangeTable.pdf .

While CMS indicates that the newly integrated OASIS-C process items are optional practices, regulators, industry and clinical experts agree that identified clinical Evidence Based Practices (EBP) — often called Best Practices (BP) — are critical to providing quality home health care. Furthermore, the decision to continue the optional approach with your staff may adversely impact agency outcomes, community marketing initiatives and eventually agency reimbursement.

It is recommended that agency leadership review OASIS-C best practice process items and plan to address agency required clinical Best Practices Standards. Written protocols for select agency best practices, as well as staff and patient education materials, may be distributed during fall training sessions. Staff competencies as well as job descriptions may need to be updated to reflect your agency decision regarding required clinical best practices.

Practice Change Considerations
Leadership knows that any change in clinical practice needs close monitoring and evaluation to ensure accurate and consistent implementation. Leadership must answer at least two difficult questions:

  1. How will your agency ensure that staff is consistently implementing revised and new OASIS-C elements?
  2. How will you support your clinicians to ensure optimal practices that enhance and refine care in the delivery of home health services?

OASIS-C RESOURCES

Final OASIS-C Document v12.4

http://www.cms.hhs.gov/HomeHealthQualityInits/Downloads/HHQIOASISCAllTimePoint.pdf

FINAL OASIS-C Manual – Item-by-Item guidance is in Chapter 3, which replaces the current Chapter 8.

http://www.cms.hhs.gov/HomehealthQualityInits/14_HHQIOASISUserManual.asp
[Scroll down and click on "OASIS-C Guidance Manual," unzip the download file and go to Chapter 3]

Comparison of OASIS-B1 to OASIS-C Draft Version 12.2 (3/4/2009) to OASIS C Final Version (August, 2009)

http://www.cms.hhs.gov/OASIS/Downloads/OASISC3ColumnChangeTable.pdf

Registration for CMS Sponsored Calls

http://www.cms.hhs.gov/HomeHealthQualityInits/02_CMSSponsoredCalls.asp

Consider these options:

  • Implement a revised agency, team and/or clinician scorecard on vital elements integral to the OASIS-C data set.
  • Review weekly or monthly Case Mix updates for all Start of Care and Recertifications.
  • Develop and use a monthly Process Report to identify how your clinicians are scoring the optional best practice items to determine the threshold your agency is achieving on these new, reportable parameters.

Keeping track of this from day one of OASIS-C implementation will arm you with data so you will not be surprised in late 2010 when process outcomes are posted to the CMS Home Care Compare web site.

Training Considerations

CMS has determined that four hours of staff training for each staff member on the new and revised assessment items will adequately meet the educational needs of home health clinicians. But seasoned educators know that practice changes, such as those evidenced in the OASIS-C, will require a longer time period to incrementally review and successfully transition from the current OASIS-B1 assessment to the revised OASIS-C document.

An incremental review of new and revised OASIS-C items using creative educational strategies beginning this fall will allow staff time to understand the changes and begin to see how to integrate the revised assessment items into their clinical practice. Begin with the best practice items and ensure your staff has the tools and knowledge to complete the screen tools and implement a relevant plan of care that addresses the screen outcomes (see list below). Offer frequent updates and the printed revised Chapter 3 Guidance to clinical staff for reference and review during and after item review sessions.

Best Practice Screens and Protocols include:

  • Falls Risk Assessment
  • Integument Assessment for Pressure Ulcer Risk
  • Standardized Pain Assessment
  • Depression Screen
  • Medication Management
  • Diabetic Foot Care
  • Heart Failure Care
  • Pressure Ulcer Treatments

Consider piloting priority OASIS-C training and field use with clinical experts and preceptors in your agency. First-hand use of new and revised items enhances lively education programs with realistic patient case scenarios to exemplify assessment variations and item scoring changes.

Clinical staff can present practice variations, as well as impact and process changes that support those field changes. Understand that dedicating time throughout the year for ongoing OASIS-C monitoring, training and individualizing clinician feedback will be critical in 2010.

CMS OASIS-C TRAINING SERIES TO START IN NOVEMBER

CMS will host a 3-part series of National Train-the-Trainer conference calls related to the OASIS-C implementation. Registration information will be provided with each call announcement and can be found at http://www.cms.hhs.gov/HomeHealthQualityInits/02_CMSSponsoredCalls.asp

The calls are free of charge and cover the topics listed below.

Date: October 22, 2009
Topic: OASIS-C Development and Impact on Agency Operations
Time: 2:30 p.m.  EST

Date: November 12, 2009
Topic: Highlights of OASIS-C Changes by Section
Time: 1:30 p.m. EST

Date: December 8, 2009
Topic: Quality Measurement and Reporting
Time: 1:30 p.m. EST

The teleconferences are scheduled to last two hours and will include a question and answer period.  Each session builds on the material presented in the previous call so CMS encourages that participants attend all three sessions.

Calls are free of charge. If you are unable to participate in a scheduled call, options to listen to or read a transcript of a call will be made available by CMS. Knowledge of the OASIS-C instrument and other related materials posted on the CMS website is important to learning as much as possible from these conferences.

Review and Update Processes that must be in place in 2010 to reinforce new education programming
Consider revising or refining your current:

  • Staff updates
  • Case Conference Applications
  • Case Scenario presentations
  • Board updates
  • In-service education activities such as mini-newsletter and e-mail updates

Set the Tone for Success in 2010
Leadership sets the pace and tone for success with any agency change and home health managers are not strangers to working in a constantly changing culture. Focused energy and positive initiatives will reinforce fundamentals for success as assessments and practices change.

Clinicians need to see how revised assessments, EBP and valid and reliable tools will help them better assess and document what they have been practicing for many years. Systematizing and standardizing these practices not only enhances clinical practice but also ensures and validates that patients and caregivers will recognize organizations and clinicians who value and implement national best practice standards.

Trisha Tulloch is a Senior Consultant with RBC Limited of Staatsburg, New York. A seasoned clinician with more than 30 years in health care practice, Trisha’s diverse experience includes leadership roles in both Home Health and Hospice.  A Registered Nurse with code credentials from the Board of Advanced Medical Coding, she is a nationally recognized speaker who provides both clinical and administrative expertise to agencies across the country.  Responsible for oversight of RBC Limited’s Health Care Division, she collaborates with industry experts and attorneys for Corporate Compliance, Fact Finding, Fraud and Abuse and Regulatory Standards.  Her specialty in coding and OASIS education and training, utilizing RBC Limited’s Integrated Oasis Solutions methodology, reflects her unique skill set to promote industry best practices. She has extensive experience and expertise in:

• Clinical Best Practices;
• OASIS Assessment & Documentation;
• CHAP & Joint Commission Accreditation;
• On-site Management;
• Reimbursement issues;
• In-service and training of home care staff;
• Hospice clinical, administrative and financial management;
• ICD-9-CM Coding;
• Corporate compliance;
• Strategic planning; and
• PPS.

Contact the author through RBC Limited: www.rbclimited.com

3 Responses to “Five Critical Steps Leaders Should Take Now to Prepare for OASIS-C”

  1. John Connor Says:

    Good luck getting them to take any of those steps.

    J. Connor
    Professional coding billing
    coding ICD 9 expert

  2. Carolyn Humphrey Says:

    John, I appreciate your comment that is likely based on a great deal of home care experience. Do you have any suggestions for our readers on ways to help home care leaders take these steps in an efficient and effective way and selling the need to do these activities to their administrators?

    Carolyn Humphrey, Editor

  3. Kristi Kirschnick RN Says:

    I don’t see this being a huge jump for my staff as we have been doing all the additional comprehensive assessments for a couple of years now. I am glad the OASIS is finally becoming a real “assessment” instead of just a technical data collection tool. If you have the right tools for your staff you will definitely see an improvement in the level of care your staff provides!

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