Home Health Coding Changes under the Home Health Final Rule

After much speculation, CMS has released the 2023 Home Health Final Rule (HHFR). It includes updates to the home infusion therapy and home health service payment rates for CY 2023. 

Revenue cycle leaders will want to pay attention to these changes from a coding perspective, because it will impact not just home health coding overall, but specifically OASIS coding

How the Home Health Final Rule Intersects with OASIS Home Health Coding 
Under the rule and with the implementation of OASIS-E, a diagnosis won’t exist to put on a recertification OASIS. Still, the orders to take care of the patient and plan of care will have to be coded [1]. 

Know that under the final rule, CMS is ending the temporary suspension of OASIS data collection for non-Medicare and non-Medicaid (home health agency) HHA patients. This means HHAs will have to submit all-payer OASIS data for the Home Health Quality Reporting Program (QRP), starting with the CY 2027 program year. This will require two quarters of data for that program year. CMS is finalizing a phase-in period that runs from January 1, 2025 to June 30 of the same year. Failure to submit data during that period will not result in a penalty [2]. 

Background on OASIS Coding for Home Health
The launch of OASIS-E was delayed because of the COVID-19 pandemic, being rescheduled for 2023 along with the expansion of the Home Health Value-Based Purchasing (HHVBP) model. This delay gave HHAs a bit more time to prepare for OASIS coding requirements and make sure their OASIS data accurately reflected the status of their home health patients. 

OASIS-E implementation launched along with the HHVBP model on January 1, 2023. This means that HHAs who haven’t started will need to begin a transition plan. While rolling out too early is no longer a concern, it will be critical to design a training plan that supports a continuous approach to education that helps clinicians understand the data elements that make up OASIS home health coding and how each of these elements aligns with their care responsibilities. 

How to Ensure OASIS Coding Accuracy
Coders face increased complications under these OASIS changes. They’re dealing with a wide range of documents from multiple providers in multiple care settings. You need to be working with coders who can perform accurate reviews while navigating the changes in information access that have come about in terms of OASIS coding under OASIS-E. These tips will help you navigate increasing complexity and ride the wave of coding changes while improving the health of your revenue cycle. 

Have a Plan
It is important that you approach OASIS coding strategically. While it is possible to simply start training your coders, you’ll likely miss critical opportunities to not only streamline your coding practices, but also to avoid the pitfalls that come with this kind of change. 

Make sure your approach doesn’t simply continue the status quo. Now is the time to align any high-level initiatives you have in improving revenues, increasing efficiency, and improving staff confidence with your OASIS coding training tactics. 

Choose the Best Metrics for Home Health Coding
Part of your OASIS coding plan should be coming up with the metrics you want to monitor as you implement change. Consider prioritizing KPIs in revenue cycle performance. For example, Net Days in Accounts Receivable can help monitor whether you have clean claim issues caused by coding. You’ll find similar results by watching metrics like Aged A/R as a Percentage of Total Billed A/R to monitor how coding issues might be slowing your revenue cycle and A/R liquidation. Aged A/R as a Percentage of Total A/R is also useful in tracking receivable aging and collectability. If it begins moving upward during your OASIS efforts after holding steady or even decreasing, you know this might be an issue. 

Work with Trained Coders
If you’re working with coders who are either newly trained on OASIS coding or aren’t catching on quickly enough, you’ll have issues in home health coding accuracy. These issues can result in unnecessary readmissions and patients not receiving the care they need. 

You will need connections with coders who have the right qualifications and who are able to maintain them without causing you significant burden. This challenge can be a complicated and expensive one, especially considering how often coding requirements change in the home health environment today. This is why many organizations consider working with outsourced OASIS coders instead of taking on the ongoing responsibilities themselves. 

Find the Right Partners
Even if you are absolutely sure you want to build your OASIS coding team in-house, you should consider the option of working with a third-party partner. 

This is because having a few conversations will help you understand the efficiency you could create. You also might be missing awareness of the potential pitfalls around OASIS coding – something you don’t want to discover through trial and error. 

To help you get this conversation started as early as possible, we’d like to invite you to contact us so we can discuss the potential benefits of finding the right OASIS coding partner today.

[1] J. Famakinwa, “How Coding Could Change Under The Home Health Proposed Payment Rule,” Home Health Care News, 23 August 2022. Available: https://homehealthcarenews.com/2022/08/how-coding-could-change-under-the-home-health-proposed-payment-rule/.

[2] “CY 2023 Home Health Prospective Payment System Rate Update and Home Infusion Therapy Services Requirements — Final Rule (CMS-1766-F),” U.S. Centers for Medicare & Medicaid Services, 21 October 2022. Available: https://www.cms.gov/newsroom/fact-sheets/cy-2023-home-health-prospective-payment-system-rate-update-and-home-infusion-therapy-services-0.

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