CMS Will Automatically Deny Claims When OASIS Assessments Can’t Be Found

Posted on Friday, November 11, 2016 1:58 PM

Agencies need to have strict parameters in place for tracking timely OASIS submissions for each single claim, which will prevent a brand new set of denials beginning 2017.

Starting April 3, CMS will automatically deny claims where OASIS assessments can’t be found in the Quality Improvement and Evaluation System (QIES), according to CMS Change Request 9585 released Oct. 27.

According to the Office of Inspector General (OIG) (HHL 3/5/12), this presents a real risk for agencies as nearly 9,300 Medicare-certified agencies failed to submit OASIS data for at least one claim in 2009.

Several factors can explain why an agency missed the window for OASIS submission. For example, the person in charge of identifying when OASIS assessments are late or not submitted might be out sick or on vacation.

CMS’ regulations require the OASIS to be submitted within 30 days of the assessment date, but the federal Medicare agency is not going to cite agencies until 40 days — this provides a small leeway for the OASIS to be processed as received, says Judy Adams, president of Adams Home Care Consulting in Durham, N.C.

CMS’ new requirement is designed to prevent fraud, adds Ann Rambusch, president of Rambusch3 Consulting in Georgetown, Texas.

Of those 9,300 Medicare agencies that failed to submit OASIS for at least one claim only 60 agencies had their payments reduced due to this in 2010, an OIG report states.

The following actions are required from agencies to prevent late submissions or non-submissions:
• Review error reports closely
• Make sure you have proper oversight involving OASIS submission issues
• Put a competent backup in place for identifying and resolving OASIS submission issues
• Consider using the same system for billing and electronic medical records
• Identify whether a specific clinician is not submitting OASIS assessments timely
• Submit OASIS at least twice monthly

Corridor’s Coding Services offers ICD-10 coding, multi-level OASIS reviews, Clinician documentation review, as well as trends and reporting. Contact us to learn more.
For the full article, please see the November 14, 2016 Home Health Line Edition.

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