Since mid-1999, the CMS and its predecessor agency, the HCFA have required all certified HHAs to systematically use the OASIS to measure functional status and medical conditions of Medicare beneficiaries receiving home health care and to send assessment data to a central repository. The Conditions of Participation for Home Health Agencies were revised in 1999 to reflect the regulation first published in the Federal Register (64 FR 3764) that stated each patient must receive from the HHA 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 achievement of desired outcomes. The comprehensive assessment must identify the patient's continuing need for home care and meet the patient's medical, nursing, rehabilitative, social, and discharge planning needs." (CFR 42 §484.55). The Conditions of Participation also require that the comprehensive assessment "incorporate the use of the current version of the OASIS items, using the language and groupings of the OASIS items, as specified by the Secretary." (CFR 42 §484.55).
A second rule, published concurrently with the initial regulations requiring the use of OASIS, provided guidelines for the electronic transmission of the OASIS data set, set out the responsibilities of the state agency or HCFA Medicare contractor in collecting and transmitting the information to HCFA, and set forth rules concerning the privacy of patient identifiable data generated by OASIS, all of which were required in order to create a PPS for HHAs.
Since October 2000, OASIS data has served as the basis for the PPS for reimbursing home health services. Since 2003, data collected through the OASIS instrument have been used by CMS to support home health care quality initiatives. OASIS data are also used by CMS to assess compliance with the Pay for Reporting requirements of the DRA of 2005. CMS views the use of the same data to support both quality monitoring and payment as their way of ensuring HHAs are not maximizing reimbursement at the expense of quality outcomes. In March 2009, CMS published a request for comments in the Federal Register regarding the use of a revised OASIS, and in July 2009 received the OMB approval to use OASIS-C. In August 2009 CMS published the final rule which established January 1, 2010 as the required date for HHAs to begin using OASIS-C.
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