I am forwarding a response from CMS regarding (below) unavoidable late OASIS transmissions resulting from payer source changes. Surveyors are looking at late transmissions and should be investigating why they are occurring (see below).
We are monitoring our transmissions and tracking these unique scenarios in preparation for survey investigations.
From: Rachel Eastwood <Rachel.Eastwood@adarahomehealth.com>
Sent: Thursday, January 9, 2025 8:51 AM
To: CMS HHA Survey Protocols <hhasurveyprotocols@cms.hhs.gov>; CMS Home Health Quality Questions <HomeHealthQualityQuestions@cms.hhs.gov>
Subject: Question-Unavoidable Late OASIS Transmissions
Good Morning,
Please see the following question below.
Question:
How would CMS expect agencies to handle scenarios involving retroactive eligibility requiring new Start of Care OASIS in order to get paid? If we are not made aware of payer
changes and they do not reflect on our eligibility checks timely, the records may be transmitted late simply due to the requirement to transmit a new OASIS SOC to capture the payer SOC date (this is not an admission to agency but an admission to a new payer
source).
Situation:
Agency billed Medicare Advantage payer UCARE Medicare for dates of services: 9/19/24 through 10/18/24. The EVS eligibility check completed the October 1st, 2024
reflected the primary payer for services was UCARE Medicare. In mid- December, agency received a call from a client’s legal representative stating the client switched to a new Medicare Advantage Plan (BCBS) in October, effective 10/1/24. This new payer did
not show in the eligibility checks completed on 10/1/24. Agency ran the 270 eligibility check in December when learning of the payer change and it did show that the UCARE Medicare policy terminated on 9/30/24 and effective 10/1/24 the primary payer was Medicare
Advantage BCBS.
Issue:
Agency would have identified the change in payer with the monthly eligibility check on 11/1/24, however the client discharged in mid-October prior to this date. Since the
agency was not made aware of the insurance change until December, the retroactive realignment occurred at that time in order to transmit a new SOC for the new payer effective 10/1/24. As a result, the OASIS transmitted 30 days which placed our agency out of
compliance with the CoP §484.45(a) . State Surveyors are using the HHA Error Summary by Agency Report to review error, -3330 “Record Submitted Late” to cite agencies for noncompliance with this requirement, even if the late transmission is not always preventable.
We were instructed by surveyors to coordinate with the OASIS help desk when unavoidable occurrences such as this occur.
Your guidance on this topic is appreciated,
Thank you,
Rachel
From: CMS HHA Survey Protocols <hhasurveyprotocols@cms.hhs.gov>
Sent: Wednesday, January 15, 2025 12:44 PM
To: Rachel Eastwood <Rachel.Eastwood@adarahomehealth.com>; CMS Home Health Quality Questions <HomeHealthQualityQuestions@cms.hhs.gov>
Subject: *External Email Message*RE: Question-Unavoidable Late OASIS Transmissions
Hi Rachel,
Thank you for your question. We always suggest keeping documentation of corrections so that if it shows up on a CMS OASIS report (pulled during an onsite survey) – the HHA
can explain the situation and possibly mitigate any CoP citations. If an HHA shows a pattern of multiple assessments with error -3330 on this report, surveyors will investigate compliance with G372, Encoding and transmitting OASIS data (§484.45(a)). Error
codes do not automatically trigger a citation. Instead,
Appendix B of the State Operations Manual directs surveyors to look for a pattern of multiple assessments with error -3330 and then discuss/investigate with the HHA. We encourage HHAs to share similar info to what you
provided in your example with surveyors when questioned.
We hope this is helpful.
The HHA Team
Rachel Eastwood, RN
Vice President of Nursing Services/Compliance Officer
Adara Home Health
25 1st Avenue NE, Suite 200
Buffalo, MN 55313
Phone- 763-682-0665
Fax- 763-682-6543
Email: rachel.eastwood@adarahomehealth.com
