CMS Provides Top 10 Home Health Survey Deficiencies and OASIS Transmission Errors

At the recent March on Washington advocacy event, representatives from the Centers for Medicare and Medicaid Services participated in a panel to discuss regulatory and policy initiatives for 2012 and beyond. The discussion centered on key topics such as payment policy, survey and certification, and an overview of medical review activities in home health.

A representative from the Survey and Certification Group provided an overview of OASIS, Process Measures, survey tools and available guidance manuals. The Powerpoint presentation included access to the many documents and resources referenced. A link to that presentation is provided at the end of this article.

In addition to citing resources, the CMS representative provided an overview of new survey protocols that went into effect in 2011 and the top ten home health survey deficiencies, which are listed below.

  • G158 – Written Plan of Care established & periodically reviewed
  • G159 – Plan of Care covers diagnosis, required services, visits, etc.
  • G236 – Record with past/current findings maintained for all patients
  • G337 – Assessment includes review of all medications
  • G121 – Compliance with accepted professional standards/principles
  • G229 – Supervisory visits if skilled care no less than once every 2 weeks
  • G143 – Coordination of Patient Services
  • G170 – Skilled Nursing Services furnished in accordance with Plan of Care
  • G176 – RN prepares notes, coordinates, informs MD, other staff of changes
  • G165 – Drugs and treatment administered only as ordered by physician

Four of the top ten survey deficiencies centered on failure to comply with plan of care requirements, a recurrent theme each year in home health surveys. Plan of care failings ranged from absence of plans of care, incomplete plans of care and failure to provide services in accord with the plan of care.

Top 10 OASIS Transmission Errors

Also, an overview of OASIS transmission errors was presented. Top ten transmission errors included:

  • 286 – Warning – Inconsistent M0090/Submission Date
  • 1000 – Fatal Record  Duplicate assessment
  • 1002 – Warning – Inconsistent record sequence
  • 1003 – Warning – Inconsistent effective date sequence
  • 320 – Warning Warning – The The submitted submitted HIPPS_VERSION must match the  calculated HIPPS_VERSION
  • 262 – Warning – Inconsistent M0090 date
  • 213 – Fatal Record – Invalid data value
  • 129 – Warning Warning — Inconsistent Inconsistent M0090 date M0090 date
  • 265 – Warning – New Patient
  • 257 – Warning – The submitted HIPPS_CODE must match the calculated HIPPS_CODE value

Of these, only duplicate assessments and incorrect data format are fatal errors. The remaining top ten transmission errors are warnings.

The Powerpoint presentation for the CMS Survey & Certification and presentation for the representative from CMS Medical Review can be accessed by clicking here.

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