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OASIS-C1

On April 1, 2014, the Protecting Access to Medicare Act of 2014 (PAMA) (Pub. L. No. 113-93) was enacted, which said that the Secretary may not adopt ICD-10 prior to October 1, 2015.  CMS spent several weeks assessing what, if any, impact this ICD-10 delay would have for our various quality reporting programs.  We have determined that the ICD-10 delay will have an impact on the Home Health Quality Reporting Program and more specifically on the implementation of OASIS-C1. 

A revised version of the OASIS-C1 data item set was approved by OMB on February 6, 2014 and this version of OASIS was scheduled for implementation on October 1, 2014.  However, five (5) of the data items contained in OASIS-C1 require the use ICD-10 codes.  Since ICD-10 has been delayed until at least October 1, 2015, we have determined that it is necessary to make interim changes to the OASIS-C1 data item set and process for reporting OASIS-C1 data to CMS. 

The following is a summary of the changes that CMS is making to OASIS-C1 and the OASIS data submission process in response to the legislatively mandated ICD-10 delay:

  1. OASIS-C1 Implementation
  1. A modified version of OASIS-C1 (referred to as “OASIS-C1/ ICD-9 Version.”)  will be created.  In this version of OASIS-C1, the 5 items that use ICD-10 codes (i.e. - M1011, M1017, M1021, M1023, M1025) will be removed and replaced with the corresponding items ICD-9 based items from OASIS-C (i.e. – M1010, M1016, M1020, M1022, M1024). 
  2. The current OASIS data set (OASIS-C) will remain in effect until 11:59:59 p.m. on December 31, 2014;
  3. The OASIS-C1 / ICD-9 version will go into effect at 12:00 a.m. on January 1, 2015 and shall remain in effect until ICD-10 is implemented or until another disposition is made by CMS;

  1. Conversion To Assessment Submission and Processing (ASAP) System
  1. Effective January 1, 2015, OASIS assessment data will be submitted to CMS via the national OASIS Assessment Submission and Processing (ASAP) system.
  2. With the implementation of the OASIS ASAP system, Home Health Agencies will no longer submit OASIS assessment data to CMS via their state databases.
  3. In order to transition data from the state databases to ASAP, the OASIS submission system will shut down permanently at 6:00 p.m. ET on December 26, 2014.  The OASIS ASAP system will be available at 12:00 a.m. ET on January 1, 2015. 
    1. From 6:00 p.m. (ET) on December 26, 2014 through 11:59 p.m. (ET) on December 31, 2014, no OASIS assessments will be accepted.
    2. The OASIS ASAP system will become available at 12:00 a.m. ET on January 1, 2015. 
  4. OASIS assessment data files submitted on or after January 1, 2015 using the ASAP system must follow version 2.10 (which supports OASIS-C) and version 2.11 (which supports OASIS-C1) of the OASIS data submission specifications.

  1. Payment Grouper Updates
  1. An updated home health payment grouper will be provided accommodate assessment submitted October 1, 2014 and later using OASIS-C and ICD-9-CM codes;
  2. An updated home health payment grouper will be provided to accommodate assessments submitted January 1, 2015 and later using OASIS-C1 and ICD-9-CM codes;
  3. We are also planning to release a home health payment grouper update to accommodate assessments submitted October 1, 2015.
  4. CMS will provide follow-up announcements at later dates regarding the release dates for the updated home health payment grouper software:
  • Grouper Update #1 –  To be implemented on October 1, 2014 for use with assessments submitted on October 1, 2014 & thereafter;
  • Grouper Update #2 – To be implemented on January 1, 2015 for use with assessments submitted on January 1, 2015 & thereafter;
  • Grouper Update #3 – To be implemented on October 1, 2015 for use with assessments submitted on October 1, 2015 & thereafter.