OASIS-C tip of the week: PCA services and OASIS

Q: We have a client that we provide PCA services for routinely, but she needs and injection every 3 months.  We provide a skilled nurse visit at that time for the injection.  Do we need to be doing an OASIS for her?

A: Assuming you are a Medicare certified provider, and that you are providing your PCA services under your Medicare certified provider and your Minnesota Class A license, the answer to your question is YES – if you provide a skilled nurse visit to your patient who is receiving PCA services routinely, you are required to complete an OASIS at the required time points.

As stated in the Federal Register 42 CFR Part 484 Medicare and Medicaid Programs:

Comprehensive Assessment and Use of the OASIS as Part of the Conditions of Participation for Home Health Agencies Final Rule:

“Background:  Under the authority of sections 1861(o), 1871 and 1891 of the Act, the Secretary has established in regulations, the requirements that an HHA must meet to participate in the Medicare program.  These requirements are set forth at 42 CFR Part 484, Conditions of Participation:  Home Health Agencies.  Unless a condition is specifically limited to Medicare beneficiaries, the Conditions of participation (CoPs) apply to an HHA as an entity and to the services it furnishes to an individual under its care. “

Reporting Outcome and Assessment Information Set Data as Part of the Conditions of Participation for Home Health Agencies Final Rule:

1.  Comprehensive Assessment:

“The Comprehensive Assessment of Patients COP reflects the patient-centered, interdisciplinary approach, and underscores our view that systematic patient assessment is essential to improving quality of care and patient outcomes.  We believe that the comprehensive assessment requirements reflect standard practice for most HHAs.  In addition , this condition requires HHAs to incorporate the use of OASIS in their comprehensive assessment.

We proposed to add a new 484.55 to require that each patient receive from the HHA a patient-specific, comprehensive assessment that identifies the patient’s medical, nursing, rehabilitative, social and discharge planning needs.  For Medicare patients, identifying the need for home care would include assessment of the patient’s eligibility for the home health benefit, including the patient’s homebound status.  (this verification of a patient’s eligibility for Medicare home health benefit including homebound status does not apply to Medicaid patients or private pay patients.)  As a result of the utility of OASIS as a case mix adjuster, we have slightly modified the appropriate populations for whom, the OASIS data should be collected.  Because OASIS data is necessary for payment purposes, it must be collected for all Medicare beneficiaries except pediatric patients, including those groups for whom OASIS is not as useful for outcome measurement as for others.  We expect HHAs will collect OASIS data on all patients served by the HHA except pre-partum and postpartum patients, patients under 18, and patients who are not receiving personal care or health services (that is patients who are receiving only services such as housecleaning, cooking and laundry).”

The skilled visit you provide to administer the injection is considered a “health service” by Medicare and Medicaid.

Accountable Care Organizations (ACOs): Patients’ Right to Freedom of Choice of Providers

Dear readers, here is another great, informative piece about Accountable Care Organizations, brought to you by Elizabeth Hogue!

Patients who are assigned or “aligned” with physicians who participate in ACOs are not required to receive services from such physicians or from any other participants in ACOs.  Patients who are aligned with physicians in ACOs still have the right to freedom of choice of all types of providers.  The Centers for Medicare and Medicaid Services (CMS) emphasizes this fact in commentary to the final regulations governing ACO’s as follows:

• “We have also been vigilant in protecting the rights and benefits of FFS beneficiaries under traditional Medicare to maintain the same access to care and freedom of choice…”

• “An ACO will not receive an assignment of those beneficiaries that choose not to receive care from ACO providers.”

• “We also noted that the strategies employed by an ACO to optimize care coordination should not impede the ability of a beneficiary to seek care from providers that are not participating in the ACO, or place any restrictions that are not legally required on the exchange of medical records with providers who are not part of the ACO.  We proposed to prohibit the ACO from developing any policies that would restrict a beneficiary’s freedom to seek care from providers and suppliers outside of the ACO.”

• “It is important to note that the term ‘assignment’ for purposes of this provision in no way implies any limits, restrictions, or diminishment of the rights of Medicare FFS beneficiaries to exercise complete freedom of choice in the physicians and other health care practitioners and suppliers from whom they receive their services.  Thus, while the statute refers to the assignment of beneficiaries to an ACO, we would characterize the process more as an ‘alignment’ of beneficiaries with an ACO, that is, the exercise of free choice by beneficiaries in the physicians and other health care providers and suppliers from whom they receive their services is a presupposition of the Shared Saving Program.”

• “…the Shared Savings program is certainly not intended to be a managed care program in a new guise.  One important distinction between an ACO and many MA organizations is that beneficiaries are not locked into receiving services from the ACO to which they are assigned, and may continue to seek care from any provider they choose.”

• “Beneficiaries who are assigned to ACOs under the Shared Savings Program remain Medicare fee-for-service beneficiaries, retaining their full freedom of choice regarding where to receive services. We therefore take this opportunity, as requested by a number of commenters, to confirm and emphasize that basic beneficiary rights are maintained under the Shared Savings Program, most especially (but not exclusively) the right to receive care from physicians and other medical practitioners of their choice outside the ACO at no penalty to the patient.”

• “The ACO model does not include the use of networks or any restrictions on where beneficiaries can receive care.”

It remains to be seen how ACOs will work in practice, but the final regulations are quite clear that patients in ACOs retain their right to freedom of choice of providers.

©2012 Elizabeth E. Hogue, Esq.  All rights reserved.

No portion of this material may be reproduced in any form without the advance written permission of the author.

A valentine for home care!

MHCA just received a lovely Valentine via our Facebook contest! Check it out:

Winner of our 2012 "Valentine for Home Care" Facebook Contest!

This card clearly demonstrates an understanding for what home care is and what home care does–a truly heartening sentiment, and that’s the best valentine of all!

Institutional inequality?

This NYT story is sad. If you don’t have time to read it, I’ll re-cap: some retirement communities are segregating their dining facilities. Healthier residents get to use the higher end, nicer dining rooms, while those who are less healthy aren’t allowed in. It’s not surprising that these policies have come to be seen as discrimination and have been subject to legal scrutiny, and it’s disheartening that people are being segregated based on their health status.

On the other hand, it should serve as a reminder that home care is equality. Home care patients get to eat in the same place as other home care patients: their own kitchen tables. Sure, some kitchen tables might be nicer than others, but no one is going to be turned away from the table due to health or disability. It’s no wonder, then, that home care is what most people want, and where most people prefer to be.

Valentine’s Day Facebook Contest!

Do you remember being a kid, and making valentines with glue sticks and cut up doilies? Writing messages in glitter? Sealing envelopes with stickers? Well, our Facebook contest is bringing back all the joy of creating valentines, only instead of creating cards for a secret crush, the object of affection in this case is home care.

One of the goals of this blog is to raise awareness about home care, and what better way to raise awareness than to use the biggest social networking site, Facebook? In order to participate in the contest, create an e-card that tells the world why you love home care. (See below for example).

Create a Valentine for home care and win!

Create your e-card and then post it to our Facebook page. You will have to “like” our page before you can post on our wall. The card that gets the most “likes” wins!

Imagine what we can do when we flood the interwebs with messages about home care, and why we love it! Go create your card now!

Earlier today, …

Earlier today, our friends at Visiting Nurse Services of New York tweeted an interesting Wall Street Journal article about doctors’ disagreements over whether to prescribe statins for people who may have elevated cholesterol but who are otherwise healthy. The article presented arguments from two doctors, one who claimed that statins prevent heart disease, and another who said that there is no proof that they prevent heart disease, while they can cause diabetes and other problems.

This got me thinking, since I recently read another article about ACOs, in which many experts agreed that the ACO model can’t be successful unless patients take responsibility for their own health. While it’s true that people need to take care of themselves, after reading the WSJ article, I all I could think was, “how are people supposed to make informed decisions about their care when all the information they get is contradictory?” Asking patients to choose between disagreeing doctors is, for some, a tall order.

Maybe the WSJ is to blame in this instance for its presentation of the issue. It’s one thing to give people a list of pros and cons–that would be useful, in fact–but to present people with one doctor saying “Yes! Take these to prevent heart disease!” and another who says “No! You might get diabetes!” is to confuse most people. These are two diametrically opposed positions–choose one, or the other. What do we want patients to do, flip a coin?

If we want patients to step up and take more responsibility for their own health, maybe we need to do a better job of communicating with them, and give them better information. Imagine your doctor prescribed statins for you. You pick up your prescription on your way home from work, and on the radio, a different doctor is talking about the dangerous side effects of statins, and how they shouldn’t be prescribed to healthy people. Are you feeling anxious yet? Somehow, I don’t think making patients anxious about the medicine they take will motivate people to be more accountable for their health.

Let’s find better ways to inform people so that they can feel better about the choices that they’re making, and in turn, feel better about being responsible for their own well being.

Does medicine need a cultural change?

I read an article in Minnesota Physician about Accountable Care Organizations and I came across and interesting quote:

Dr. David Thorson, MD: “I think it is trying to get physicians to realize that the way we provide care needs to change. I don’t think there’s any question that we can’t continue to do what we’ve been doing and have a healthcare system that will stay afloat. the government is trying to do a technical change to force cultural change within clinics. And cultural change is hard. Technical change is a lot easier. The thing we talk about all the time is how we have to change the culture of how we deliver care. This is an awkward time because we’re trying to change culture before payment has been changed. It’s taking a very big leap of faith.”

I found the idea of a cultural change in the medical community to be a very intriguing idea. What do you think, dear readers? Is a cultural change what is needed? If so, what would that change be, and how would we make it happen? Type your answers into the comments!

Coding tip of the week: How do I code residual effects from a traumatic brain injury?

I hope you’re having a nice week, dear readers! Here is this week’s coding tip, brought to you by Pathway Health Services.

Q:  How do I code residual effects from a traumatic brain injury where the initial trauma occurred long ago but we are still dealing with the sequelae such as gait abnormality, confusion, memory loss or seizures?

A:  What you describe would be called late effects of a traumatic brain injury.  These codes are in the 907 family.  The entire section 905 thru 909 deals with late effects of injuries.  One caution – unlike late effects of CVA (438 codes) where the late effect code comes first followed by additional codes to further describe the late effects – late effects of injury codes are done exactly opposite.  First list codes that describe the late effect (eg gait abnormality, memory loss) then list the 907.XX code.

4 Steps to Proper Contact Lens Care

Do you have patients who wear contact lenses? Do they use butter to clean them? Evidently some people do. According to a story on NPR, most contact lens wearers don’t take proper care of the lenses, which is problematic because it can lead to ulcers and infections–and even blindness. I myself am a contact lens wearer, and I learned a few things from this article about proper lens care, and I resolve to make sure I do these things from now on. Help prevent eye infections in your home care patients by making sure they follow these steps:

1. Change the solution. Many people don’t remember to change the solution that their contacts soak in over night; instead, they simply add more solution. It is important to change the solution, as last night’s solution is already full of bacteria. Imagine it’s your kitchen sink. You wash your dishes in the sink and the water gets dirty. Would you let that water sit all day, and wash your dishes again in the same dirty water? No? Then don’t do the same thing with contact lenses.
2. Let the case air dry. The case needs to dry out so that bacteria don’t grow in it. Get a new lens case every month.
3. Use solution–not beer, not lemonade, not butter–to clean your lenses. Do I really need to explain this one? Make sure your home care patients know to only use solution to clean their contacts. Full stop.
4. Don’t sleep in your lenses. Sleeping in your lenses increases the likelihood of infection. Don’t do it.

When you’re in the patient’s home, you will have the opportunity to see how the patient takes care of his or her lenses, and you will be able to intervene if you see problems. The bright side is that these problems are relatively easy to correct. Make sure your patients know that proper lens care can save them a lot of pain and money.

Finally, are you taking good care of your lenses? As a home care worker, you work long hours. Sometimes you get home after a long day and you want to go straight to bed–you’re too tired to take your contacts out. Even though proper care can seem time consuming (particularly when you’re exhausted), but proper lens care will save you pain and money in future as well.

Home Care for Alzheimer’s and Dementia

I think there’s a misconception that home care is great for everyone except for people with Alzheimer’s and/or dementia. It makes sense to think that it is just plain unsafe for dementia patients to be anywhere but a memory care unit, but the truth is, patients with Alzheimer’s and dementia can thrive at home with help from home care. In fact, people with dementia can do better in their own homes, as moving them to unfamiliar surroundings–like a family member’s house or a nursing home facility–can be unsettling for people with dementia.

You don’t have to take my word for it, though:

This is especially important for those suffering from these terrible illnesses, because often times a change in surroundings can be very scary. Even moving from their own home to the home of a family member can be a rather unsettling experience for everyone involved. But with an in home caregiver, the dementia or Alzheimer’s care patient can receive the level of quality care they need and deserve while staying in the familiar surroundings they are most comfortable with.

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