OASIS Focus: Prepare for new COVID-19 measure. Plus: changes to discharge guidance

A new OASIS item in 2025 will track patients’ COVID-19 vaccination status if proposed changes are finalized later this year.

The new proposed OASIS item will appear in OASIS section O and will measure whether a patient’s COVID-19 vaccination is up to date, CMS stated in a June notice on its website.

The proposed response options would then be either:

  • “0- No, patient is not up to date”
  • “1- Yes, patient is up to date”

Get ready for new OASIS item

The COVID-19 vaccination item would be added to the OASIS and collected at the transfer, discharge and death at home to capture this information across all Medicare-certified home health agencies.

Agencies would be able to use all sources of information available to obtain the vaccination data, such as patient interviews, medical records, proxy response, and vaccination cards provided by the patient/caregivers.

With new OASIS item comes new measure

Data from the new OASIS item would feed the proposed new measure, COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date” (Patient/Resident COVID-19 Vaccine), the 2024 proposed home health rule states.

If finalized this measure would be added to the home health quality reporting program (HH QRP) in CY2025.

According to the rule, the new measure would be displayed on Care Compare beginning with the January 2026 refresh or as soon as technically feasible.

The new COVID-19 vaccine measure would report the percentage of home health quality episodes in which patients were up to date with their COVID-19 vaccinations as defined by Centers for Disease Control and Prevention (CDC) guidelines on current vaccination.

Note: The definition of “up to date” on COVID-19 vaccines may change based on the CDC’s latest guidance.

The measure would require the collection of COVID-19 vaccination data at the end of each quality episode. This would include OASIS collection when a patient is transferred to an inpatient facility, with or without discharge (M0100 RFA 6 or 7), when a patient experiences a death at home (M0100 RFA 8) and when a patient is discharged from agency - not to an inpatient facility (M0100 RFA 9).

Data would be collected using a standardized item harmonized across the post-acute care settings as collected on the OASIS for home health patients, the IRF-PAI for IRF patients, the LCDS for LTCH patients, and the MDS for SNF residents.

The measure would use information from the OASIS to obtain raw rates of the number of home health quality episodes in which patients were up to date with their COVID-19 vaccination.

The measure would be reported using one quarter of data and updated quarterly.

OASIS Quarterly Q&A: Updated discharge guidance

Agencies should not submit a discharge OASIS in the event of a single visit in a quality episode, according to updated guidance from CMS in the July 2023 CMS Quarterly OASIS Q&As, released July 18.
 
These instructions supersede previously published guidance that stated the discharge OASIS was “not required” in the situation of a single visit quality episode.
 
The quarterly Q&A includes seven questions and answers, including what an agency should do if an OASIS reviewer has questions about an OASIS assessment, but the clinician is no longer with the agency.
 
CMS notes an error which can be validated through documentation as a true error can be corrected. But a discrepancy between two data items cannot be changed when the clinician cannot be contacted and should be submitted with the original responses.
 
“The comprehensive assessment, including the OASIS, is a legal document and when signed by a clinician, the signature is an attestation that all information contained in the document is truthful and accurate,” CMS states.
 
Read the full Q&A at: https://qtso.cms.gov/system/files/qtso/508_CMS_OAI_2nd%20Qtr_2023_QAs_July_2023_final.pdf.

View CMS’ COVID vaccine measure specifications at: https://www.cms.gov/files/document/patient-covid-vaccine-measure-hh-qrp-specifications.pdf.