Eli Home Health 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 transmit OASIS (tool used by CMS to collect certain patient information) data for each completed OASIS assessment to the Centers for Medicare & Medicaid Services (CMS) system within 30 days of completing the assessment of the beneficiary for 46 of 46 OASIS assessments submitted from 10/01/24 to 9/30/25. Failure of the agency to transmit OASIS data within the required time frame prevented the agency’s patient data from being made available to CMS for analysis to evaluate the agency performance levels in the provision of patient care. Findings The surveyor reviewed the OASIS Error Detail Report for the agency in the IQIES portal on 12/7/2025, as part of the preparation for the survey. The report documented 46 late assessments transmitted from 10/01/2024 to 9/30/2025 were submitted more than 30 days after the M0090 (the date of completion of the assessment.) During the entrance conference and interview on 12/8/2025 at 10:30 AM with the Administrator (ADM) the surveyor noted the late submissions found during survey preparation and asked for OASIS final validation reports from 10/01/2024 to 9/30/2025. Record review of the QAPI program did not reveal a Performance Improvement Plan (PIP) for OASIS submission. The surveyor reviewed the OASIS Agency Final Validation (11/14/24 to 10/28/25) reports provided by the agency which documented the late OASIS submissions with the comment “Record Submitted Late: The submission date is more than 30 days after M0090 on this new record.” The report revealed 6 OASIS records had been submitted after 30 days. Record review of Texas Health and Human Services provided a “Long Term Care Regulation Provider Letter” (PL 19-22) dated 7/2/2025 to Home and Community Support Services Agencies (HCSSAs). This provider letter was updated to inform home health agencies (HHAs) of the Centers for Medicare & Medicaid Services (CMS) requirement, in accordance with the Code of Federal Regulations, Title 42, Chapter IV, Subchapter G, Part 4841, that beginning July 1, 2025, Medicare-certified HHAs must collect and report OASIS data on all adult patients, 18 years and older, who receive skilled care services, including those with non-Medicare and non-Medicaid payer sources, and those who self-pay. In an interview 12/10/2025 at 11:56 am with the Director of Nursing (DON), the surveyor asked about the process for OASIS. The DON stated, “I submit it [OASIS] within 5 days of the assessment. It [OASIS] is reviewed then it is sent back to me for signature.” When asked who was responsible for transmitting the OASIS the DON stated, “the Administrator.” The surveyor asked how late submission of the OASIS assessments could affect the patients. The DON stated, “the record may not have the correct diagnosis.” In an interview 12/10/2025 at 2:45 pm with the Administrator (ADM), the surveyor asked who was responsible for transmitting the OASIS. The ADM stated, “a biller in a different office. They [biller] are contracted with the agency. [Biller] submits it and emails me right away that it [OASIS] has been submitted or if there are any issues with submission.” Surveyor asked if there could be any reasons the OASIS assessments might have been submitted late. The ADM stated, “if the nurse doesn’t complete it timely.” The surveyor asked how late submission of the OASIS could affect the patients. The ADM stated, “the [patient] may have the wrong diagnosis. It [late submission] affects the payment.” The agency had a policy (IM.10) titled, “Timeliness” dated 01/13/18. The policy read in parts: “…Policy: Agency will ensure timely provision of service and services to meet the client’s needs in compliance with all federal and state laws and Regulations. …Procedure: All Agency staff, and physician/physician office staff as appropriate, will be oriented to the following parameters: … A. 17. Encoding and transmission of OASIS data to CMS (Centers for Medicare and Medicaid) is performed at least monthly and prior to billing. The OASIS is required to be transmitted to CMS within thirty (30) days of the date the assessment is completed (M0090)…” The agency had a policy titled: “OASIS Collecting, Encoding, and Transmitting” (IM.11) revised dated 1/13/18. The policy read in part: “…Procedure: …C. Encoding and transmitting OASIS data. 1. The Agency must encode and electronically transmit each completed OASIS assessment to the CMS system, for each beneficiary with respect to which information is required to be transmitted within 30 days of completing the assessment of the beneficiary. …3. OASIS must be transmitted for all Medicare patients, Medicaid patients, and patients utilizing any federally funded health plan options that are part of the Medicare program (e.g., Medicare Advantage (MA) plans). OASIS must also be transmitted for all Medicaid patients receiving services under a waiver program receiving services subject to the Medicare Conditions of Participation. a. Submission of OASIS is required for all patients with payer source scored 1-4 in M0150. 4. Exceptions to the transmittal requirements are patients: a. Under age 18; b. Receiving maternity services; c. Receiving housekeeping or chore services only; d. Receiving only personal care services until further notice; and e. Patients for whom Medicare or Medicaid insurance is not billed…””