Key Home Health Care

“Encoding and transmitting OASIS CFR(s): 484.45(a) Standard: An HHA must encode and electronically transmit each completed OASIS assessment to the CMS system, regarding each beneficiary with respect to which information is required to be transmitted (as determined by the Secretary), within 30 days of completing the assessment of the beneficiary. This Standard is not met as evidenced by: Based on record review and interviews, the agency failed to encode and electronically transmit each completed OASIS (Outcome and Assessment Information Set) within 30 days of completion date of the assessment. This deficient practice had the potential to affect all 165 total patients according to the agency’s current active census. Findings: Review of the agency’s revised policy dated 11/18/2024 and titled “Comprehensive Assessment” revealed, in part: Policy: [Provider] electronically reports all OASIS data collected in accordance with federal regulations 484.45(a) (b) (c) (1) (2) (3) (d) related to encoding and transmitting of OASIS data. Review of the Center for Medicare and Medicaid Services (CMS) update to the 2023 Home Health Prospective Payment System (PPS) Final Rule revealed a home health agency (HHA) must submit all payer OASIS data beginning 07/01/2025, with the following action items, in part: January 1, 2025-June 30, 2025: Maintain OASIS data collection and submission for all skilled Medicare and/or Medicaid patients. OASIS data collection and submission for Non-Medicare/Non-Medicaid patients is voluntary. Review of the agency’s OASIS Agency Final Validation Report revealed 1 out of 1 record, with a completion date of 06/22/2025. Further review revealed a submission date of 07/31/2025, which was more than 30 days after the date of completion. Further review revealed this beneficiary’s pay source, per the agency’s demographic record, was Veteran’s Administration (VA) Community Care primary and a Medicare-Advantage plan secondary. Review of the above beneficiary’s Recertification OASIS completed on 06/22/2025 revealed the following, in part: Section M0150: Current Payment Sources for Home Care: 2- Medicare (HMO/Managed Care/ Advantage Plan), and 7- Other Government- (VA). On 08/06/2025 at 3:45 p.m., an interview was conducted with S2DON. S2DON stated she was responsible for transmitting all OASIS data for the agency. S2DON stated OASIS should be transmitted within 30 days of the completion date. S2DON confirmed the CMS OASIS submission guidelines above and agreed only Non-Medicare and Non-Medicaid beneficiary OASIS submissions were voluntary and exempt from the OASIS data submission rule applied through 06/30/2025. S2DON confirmed the above OASIS submission date of 07/31/2025 and the beneficiary’s payer source was Medicare-Advantage secondary. S2DON confirmed the beneficiary’s OASIS completed on 06/22/2025 should have been submitted within 30 days of the completion date and was not. On 08/06/2025 at 4:00 p.m., an interview was conducted with S1ADM. S1ADM stated OASIS should be transmitted within 30 days of the completion date. S1ADM confirmed the CMS OASIS submission guidelines above and agreed only Non-Medicare and Non-Medicaid beneficiary OASIS submissions were voluntary and exempt from the OASIS data submission rule applied through 06/30/2025. S1ADM confirmed the above OASIS submission date of 07/31/2025 and the beneficiary’s payer source was Medicare-Advantage secondary. S1ADM confirmed the beneficiary’s OASIS completed on 06/22/2025 should have been submitted within 30 days of the completion date and was not.”

“Reviewed, revised by physician every 60 days CFR(s): 484.60(c)(1) The individualized plan of care must be reviewed and revised by the physician or allowed practitioner who is responsible for the home health plan of care and the HHA as frequently as the patient’s condition or needs require, but no less frequently than once every 60 days, beginning with the start of care date. This Element is not met as evidenced by: Based on record reviews and interviews, the agency failed to have the Plan of Care (PoC) reviewed and revised by the physician no less frequently than every 60 days, beginning with the Start of Care (SOC) date for 1 (#4) of 10 (#1, #2, #3, #4, #5, #6, #7, #8, #9 and #10) sampled patients reviewed. This deficient practice had the potential to affect all 165 patients according to the agency’s current active census. Findings: Review of the agency’s revised policy, dated 11/18/2024, and titled, “Comprehensive Assessment” revealed, in part: Policy: The Comprehensive Assessment shall be updated and revised by the appropriate skilled professional to ensure the Plan of Care is individualized to meet the patient’s needs and to address changes in the patient’s clinical status in conformance with home health agency (HHA) policy, applicable state and federal laws and regulations and accrediting organization standards as often as the patient’s needs require, but no less often than every 60 days from start of care. Review of Patient #4’s clinical record revealed Patient #4’s SOC date was 02/22/2025. Review of Patient #4’s certification period of 04/23/2025 through 06/21/2025 revealed the patient’s physician electronically signed the PoC on 06/27/2025. Further review revealed the physician did not review the PoC within 60 days of the beginning of the certification period. On 08/05/2025 at 2:12 p.m., an interview was conducted with S2DON, and Patient #4’s PoC for certification period of 04/23/2025 through 06/21/2025 was reviewed. S2DON confirmed Patient #4’s physician did not review or sign the PoC within the required 60 day period. On 08/06/2025 at 4:00 p.m., an interview was conducted with S1ADM. Patient #4’s PoC for certification period dated 04/23/2025 through 06/21/2025 was reviewed. S1ADM confirmed Patient #4’s physician did not review or sign the PoC within the required 60 day period.”