Contrary to popular belief you will NOT NEED multiple clinicians (nurses and therapists) completing the new OASIS-D, OASIS Home Health assessment. Only one nurse OR one therapist can complete the new OASIS-D GG0130 and GG0170 questions perfectly well. If the admitting clinician is able to accurately document prior functional status of self-care, mobility, and stairs, preliminary – and accurate - goal setting can be performed by nursing OR therapy.
What’s the reason for OASIS-D?
The new OASIS-D focuses on the patient's need for therapy and requires the HHA to establish clear measurable therapy goals. Its purpose is to make the agency provide measurable value for the episode by requiring the HHA to establish up to 20 rehabilitation goals for discharge.
OASIS-D introduces functional levels of 27 different ADL capabilities that determine a patient’s need for therapy. The clinician must select a goal for each item and its expected that the goal will be met within the 60 day episode.
OASIS-D is the beginning of the implementation for “PDGM” – Patient Diagnostic Group - Model which will go into effect in 2020.
The proposed PDGM model, required by the Bipartisan Budget Act of 2018, is intended to remove current incentives to over-provide therapy services and changes the 60-day episode of care unit of payment to 30 days according to CMS. Also, a new set of groupings for the patient – diagnosis and functional levels – will be introduced that determines the patient’s reimbursement for the new 30-day episode. The PDGM model is planned for implementation on January 1, 2020.
Why All Those New GG questions?
On January 1, 2019 HHAs will be held accountable for achieving the established goals established at Start of Care to provide measurable value for all those therapy visits – which until now – have been provided without a system of checks and balances
If therapy is indicated, the clinician will select the patient’s CURRENT level of function - for 27 ADL and IADL items – and a GOAL to be achieved for each of the 27 items.
G0100 is the New Bellwether…
It is not necessary to have multiple clinicians entering the home doing multiple iterations of the OASIS-D assessment - at great cost to the HHA and at create inconvenience to the patient and family. As long as GG0100 Prior Functioning can be ascertained from the patient/family AND the patient’s current status (M18XX) is worse than the patient’s prior status, realistic goals for GG0130 and GG0170 can be established.
Since the implementation of OASIS in 2000 HHAs have documented the amount of therapy the patient will need in the Start of Care assessment. The problem, now mitigated by OASIS-D, is the lack of direct correlation between the amount of therapy provided and the achievement of improvements ADL and IADL functionality.
The addition of new GG0130 and GG0170 questions introduces a new paradigm of accountability between therapy provided and measurable goals achieved on discharge. Like all OASIS prior to this one, these questions will continue to evolve on an annual basis.
Why is GG0100B Prior Mobility Functioning the Primary Indicator for Physical Therapy?
Since the patient’s safety in her/his home is a number one concern of the home health clinician, making sure the patient has the necessary services is very important. Prior functioning – as indicated by the answer to GG0100B - establishes the justification for rehabilitation. If the patient prior mobility functioning was ‘dependent’ on GG0100, physical therapy is NOT justified. If prior mobility was independent OR needed some help, and current functioning documented on M1850 and M1860 indicates deterioration, physical therapy IS indicated.
Make Sure GG0170 SOC Performance is Consistent with M1850 Transferring and M01860 Ambulation
If the patient will receive Physical Therapy for transferring and mobility, make sure your answers to the GG0170 questions A – P are consistent with the answers to M1850 and M1860. For example, if the answer to M1860 Ambulation/Mobility is “3 - Able to walk only with the supervision or assistance of another person at all times”, make sure your answers to GG0170 questions A1 – P1 are ‘03’ or ‘04’. If the patient is currently dependent, make sure answers to GG0170 questions A1 – P1 are ‘05’ or ‘06’.
Make Sure GG0170 Goals are Consistent with GG0100B Prior Functioning
If the patient’s prior mobility function was ‘independent’ or ‘needed some help’, record GG0170A2 – GG0170P2 consistently with GG0100B. In other words, if the patient was independent in mobility on GG0100B, the recommended goals for GG0170A2 – P2 are ‘05’ or ‘06’.
Medicare allows you to skip GG0100…but you shouldn’t.
The most important indicator on how many visits the patient should receive is based on the availability of a competent caregiver…established under: (M1100) Patient Living Situation: If the patient has only sporadic help, therapy utilization should be higher-than-normal., If the patient has regular help – therapy utilization should be normal.
When is NOT KNOWING the prior function acceptable?
The only time it is acceptable to skip GG0100B or not answer this question with a definitive answer of prior functioning level if is the patient is confused and/or an inaccurate historian, there’s no caregiver to provide the information and no other historian knowledgeable of the patient’s history to provide the information.
If the patient was wheelchair-dependent…
If the patient was wheelchair-bound, chair-bound or bed-bound, the answer to GG0100B should be 9 – Not Applicable.
How do you determine GG0170 Goals if you don’t know GG0100 Prior Status?
Up until this point a registered nurse is qualified to answer all of the GG questions as long as s/he has assessed M1860 accurately and knows the patient’s prior function, cognitive level and availability of a competent caregiver.
If we DON’T know the patient’s prior level of functioning the additional assessment of the Physical Therapist is indicated.
How do risk factors affect utilization?
Although risk factors like confusion, depression, multiple medications affect the patient’s teachability, the more relevant risk factors for safe mobility are impaired vision and pain. The existence of any risk factors will increase the utilization for physical therapy.
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