Perform audits and provide swift feedback to correct early mistakes

 

Don’t wait to address problems with your OASIS-E2 implementation. Correcting course now will keep issues from ballooning into larger problems that are more difficult to fix over time.

 

The OASIS-E2 was effective for assessments as of April 1. The agencies that do the best with regulatory changes are not the ones that avoid the mistakes — they’re identifying mistakes and quickly and correcting them early, says Leigh Ann Hutchens, founder and president of Clover Consulting LLC.

 

OASIS accuracy is vital to securing a payment increase under Home Health Value-Based Purchasing, and it impacts your ability to get top scores on quality measures and Star Ratings on Care Compare.

 

There were only a handful of updates with OASIS-E2, but these small changes can create a real impact if you aren’t carefully managing the rollout, Hutchens says.

 

For example, items assessing hearing, vision and language have been added at the resumption of care (ROC). Clinician training on this change may have just been a bullet point for some providers, but it’s important that this is accurately captured at ROC, Hutchens stresses.

 

The addition of hearing, vision and communication items at ROC is not just a documentation change, she says. It directly supports more accurate risk adjustment for functional outcome measures. Missing or inaccurately reassessing these items can skew outcome data and agency performance scores.

 

“The key here is ‘reassessment.’ This is where agencies will get it wrong,” she says. “Clinicians must reassess sensory and communication status and not simply copy the previous response from the start of care.”

 

For example, the patient could have some type of hospital-associated delirium after discharge, she notes. Or they could have lost their hearing aid in the hospital.

 

As a starting point, you should be auditing the first 20 OASIS-E2 assessments from start of care and resumption of care to identify documentation trends and correct mistakes quickly, Hutchens says.

 

“Without early monitoring, errors may become widespread long before they’re detected,” she says.

 

Top agencies are doing targeted education based on real charts — they’re addressing specific mistakes clinicians are making, Hutchens says.

 

Common examples include misinterpretation of renumbered items, missing or recopying those sensory items at ROC and fall classification errors, she says.

 

Provide clinicians with feedback within 24 to 48 hours to allow for rapid correction and stronger documentation habits.

 

“The goal is to identify trends, recognize the patterns before those errors repeat, across dozens of charts,” Hutchens says.

 

When helping clinicians with trouble spots, provide direct examples from their documentation, she notes. “This helps to illustrate exactly what needs to change.”

 

After providing the feedback, the next step is focused education on the specific issue. This may include reviewing OASIS guidelines or re-education on clinical documentation expectations within your agency.

 

“After education is provided, continue reviewing the next several assessments that have been completed by that clinician to confirm improvement,” Hutchens says

 

The agencies navigating OASIS-E2 most successfully right now are not just educating, she says. They are implementing structured audit programs, providing rapid feedback loops and using real-time data to drive targeted clinician improvement.

 

Recognize that the issue may not be due to your clinicians.

 

Among the changes with OASIS-E2, some items have new numbering and skip patterns. This requires careful review of your EMR to make sure it accurately addresses each change.

 

Hutchens notes that one agency that had trained its staff on a past OASIS update found later that the EMR introduced an error in its system.

 

“This created confusion that turned into a trend across more than 40 charts,” she says. “That’s why education alone isn’t enough.”

 

Verify that assessment templates, item numbering and skip patterns are functioning correctly in your EMR, Hutchens says.

 

For example, M0069 (Gender) has been replaced with A0810 (Sex). You’ll want to make sure that your EMR has the new question in the appropriate section of the assessment.

 

Other important notes include:

 

Check consistency. As you’re reviewing OASIS assessments, keep in mind that surveyors will be looking for inconsistencies in what your clinicians have in the assessment and what’s shared in visit documentation.

 

“When these elements don’t align, it raises questions about the accuracy of the assessment and puts you in the crosshairs for negative survey findings,” Hutchens notes.

 

Document vaccinations, where warranted. The updated OASIS-E2 removed the question about the patient’s COVID-19 vaccine status, but Hutchens notes this can still be documented elsewhere in your assessment, depending on your agency policies.

 

Keep AI in its proper place. The updated OASIS-E2 Guidance Manual provides a clear role for artificial intelligence (AI) as a tool. Software cannot answer OASIS questions, generate the final coded responses or automatically complete the assessment, Hutchens stresses.

 

“AI may suggest possible answers if the clinician confirms the response,” she says. “It may scrub charts, and it may do quality assurance. But remember, AI does not replace human auditing, especially over these next several months.”

 

 

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