Home Health Under Increase Scrutiny OIG Says Industry NonCompliant in Assessments and Reporting

When a beneficiary begins home health care, and at regular intervals thereafter, a registered nurse or rehabilitation therapist conducts a comprehensive assessment of the beneficiary using the OASIS, a standardized dataset. Home Health Agencies (HHAs) use the OASIS to assess patients' continuing need for home care and to identify patients' medical, nursing, rehabilitative, social, and discharge-planning needs.

A recent report by the Office of Inspector General evaluated OASIS data submission from 2009 and the extent to which CMS oversaw the accuracy and completeness of OASIS data that HHAs submitted. They also evaluated whether the 2-percent payment reduction for HHAs was enforced and compared claims from 2009 against OASIS data submission.

The analysis found that HHAs were deficient in meeting two Federal reporting requirements for OASIS data: that HHAs submit OASIS data for all Medicare beneficiaries they serve and that they submit them within 30 days from the date of the patient assessment.

Medicare reimbursement and consumer information presented on CMS's Web site depend on accurate and timely submission of OASIS data. In addition, State survey staff use OASIS data in surveying and certifying HHAs to ensure that HHAs are meeting all Conditions of Participation (CoP) required by Medicare.

CMS requires HHAs to submit OASIS data to their States for all Medicare beneficiaries they serve. State agencies are responsible for collecting and managing OASIS data. An HHA's failure to submit data should result in a 2-percent payment reduction to its home health market basket index increase for a year. CMS works with Medicare contractors to identify HHAs that have submitted claims but have not transmitted any OASIS data.

• HHAs did not submit required OASIS data for 6 percent of claims in 2009, which represented over $1 billion in Medicare payments. Submitting OASIS data did not become a Medicare condition of payment until January 1, 2010.


• Eight-five percent of HHAs did not submit OASIS data for at least one claim. Over half of those HHAs did not submit OASIS data for at least 10 claims in 2009.


• From 2007 through 2010, CMS penalized only 199 HHAs by assessing the 2-percent payment reduction for not submitting OASIS data. CMS officials told OIG it penalizes only those HHAs that failed to submit any OASIS data for that year. An HHA needs to submit only one OASIS out of potentially hundreds or thousands during the yearlong reporting period to avoid the 2-percent payment penalty.


• HHAs submitted 15 percent of OASIS datasets late.


• States showed that they provided training and support for OASIS and that most restricted access to the data. However, they conducted limited data analysis or review of the data's accuracy. Forty-seven States reported that they did nothing beyond CMS automated checks. Only three States reported that they further validated data by checking for missing data and reconciling duplicate patients. No States reported conducting analyses to ensure that the OASIS data accurately reflected patients' conditions at the time of assessments.


• CMS did not review OASIS data collected by States for accuracy or completeness.


• CMS did not validate States' processes for monitoring submitted OASIS data.

The OIG recommend that CMS:

1. Identify all HHAs that failed to submit OASIS data and apply the 2-percent payment reduction to them.


2. Establish and implement enforcement actions for HHAs that submit OASIS data after the 30-day deadline.


3. Develop clear guidelines that delineate expectations for States regarding timely and accurate OASIS data.

CMS concurred with the first recommendation, but it did not concur with the second and third recommendations. CMS is pursuing a plan of action consistent with the first.

The OIG recommended that CMS should work with States outside the survey process and develop guidelines that States could follow to improve the quality and accuracy of OASIS data.

With increased scrutiny of home health care and more measurements emerging to track home care, the industry seems poised for a shakeup, weeding out the bad apples and keeping top performers. Consumers will get wise to all of this as well and will be shopping on quality, price and overall experience.

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