Rosy in Home Services Inc.

“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 interview, the Agency failed to encode and electronically transmit completed OASIS assessment to the CMS system and failed to submit an attestation letter to HHSC at least every three months when claiming exemption to compliance with OASIS submission, as required in PL 19-22. The failure resulted in quality data essential for ongoing improvement of the effectiveness of home healthcare and patient outcomes not being reported to CMS within the required timeframes. Findings included: Review of the document titled, “Long-Term Care Regulation Provider Letter: Number PL 19-22,” issued on 7/2/2025, read in part: “OASIS is a group of standard data elements Medicare-certified HHAs integrate into their comprehensive assessment, to collect and report quality data to CMS using the national internet Quality Improvement Evaluation System (iQIES). The comprehensive assessment, including OASIS, is required to be collected by Medicare-certified HHAs on all skilled care patients.” Further review of the document revealed the following: “Licensed and Certified Home Health Services (L&CHHS) agencies claiming an exception to compliance with OASIS submission requirements must attest this intention to HHSC at least every three months.” Review of an email with OASIS Coordinator 1, dated 3/16/25, revealed the following statement in response to an inquiry of whether they had been submitting the required attestation letters: “I have not received any communication including attestation letters from the agency. But they are responsible for following all regulations including the PL 2019-22 effective 7/01/25 that HHSC sent out to all HHAs indicating attestation letters are due at least every 3 months when not submitting OASIS Data to CMS.” In an interview with the Administrator at 1:30 PM on 3/18/26, the Surveyor asked him if they had transmitted completed OASIS assessments to CMS within 30 days of completing the assessment. She stated that they did not because that had no skilled patients in the last 4 years. The Surveyor asked her if they had then been submitting the required attestations on why they are not submitting OASIS data to HHSC. The Administrator did not know and directed the Surveyor to the Alternate Administrator. In an interview with the Alternate Administrator at 1:25 PM on 3/18/26, the Surveyor confirmed that it was his responsibility to keep up with OASIS requirements. The Surveyor asked him if they had transmitted completed OASIS assessments to CMS within 30 days of completing the assessment. She stated that they did not because that had no skilled patients in the last 4 years. The Surveyor asked her if they had then been submitting the required attestations on why they are not submitting OASIS data to HHSC. The Alternate Administrator provided his Medicare Balance Credit Report that he had been submitting to the CMS. The Surveyor explained those were for billing and were not the required attestation letters. The Surveyor showed him the requirements in PL 19-22 and he stated he did not realize this was a requirement. The Surveyor asked him if they had submitted the letters and he stated that he had not because he did not know he was supposed to and did not know how. In a joint interview with OASIS Coordinator 1 at 1:41 PM on 3/18/26, the Alternate Administrator, and the Administrator, OASIS Coordinator 1 explained the requirement to the agency staff and notified them that she had not received any attestation letters from them, and that the last time they submitted an assessment to OASIS was in 2021. She notified them that this was considered noncompliance. OASIS Coordinator 1 notified the Alternate Administrator and Administrator that PL 19-22 had gone out as an alert to all providers, and that it was their responsibility to be aware of any requirements regarding the conditions of participation in order to retain their certification, even if they did not currently have patients receiving skilled services. The Alternate Administrator and Administrator stated their understanding. In an interview with the Administrator and Alternate Administrator at 2:00 PM on 3/18/26, the Surveyor asked them how not meeting the OASIS submission requirements could affect patient care. The Administrator stated that she did not think it affected patient care since they are not currently providing skilled services, and it did not affect the services they provided through PAS. The Administrator stated that it was still important that they submit the letters to meet the requirements to maintain their certification so they can provide skilled services in the future.”