*Information updated on February 17, 2023 to reflect the new Medicare rules and the end of the PHE*
Can occupational therapists initiate the OASIS Start of Care? Yes!
The question is…
- How do we spread the word? and
- Under what circumstances can OTs initiate the OASIS?
Podcast: HH OASIS & Value-Based Purchasing
Podcast: Is CMS changing its policy about if OT can initiate the OASIS in Home Health?
Medicare Patients Receiving Home Health Under Part A
Occupational therapists have been able to initiate the OASIS in therapy-only situations since January 1, 2022. However, this announcement was missed by many since it overlapped with the temporary flexibilities afforded by the COVID-19 Public Health Emergency (PHE)
Under the COVID-19 PHE, CMS issued a special waiver allowing occupational therapists, physical therapists, and speech-language pathologists could initiate the OASIS Start of care for Medicare Part A patients in ALL cases. This waiver will expire when the PHE ends on May 11, 2023. This temporary waiver intended to help relieve some of the responsibility on nurses and to allow patients to receive access to care more easily.
When did this change?
After many years of advocacy, we had a HUGE win for OT in home health. The language of the Medicare Home Health Flexibility Act was signed into law in December of 2020 as part of the Consolidated Appropriations Act of 2020 after advocacy from AOTA and OT Advocates.
This legislation required CMS to develop a permanent rule change to allow OTs to initiate and complete the comprehensive start of care assessment in therapy-only cases. Therapy-only cases are when skilled nursing is not included on the initial home health order.
This update can be found in the Home Health CY 2022 Final Rule from CMS and in the Home Health Conditions of Participation – 42 CFR §484.55
Some agencies were originally hesitant to allow OTs to initiate the OASIS due to the public health emergency flexibility being temporary. Plus, we never could have predicted it would last for over three years. Now that we have a permanent solution, there should be no hesitance in training and utilizing OTs to initiating and completing the comprehensive start of care.
Non-Medicare Patients Receiving Home Health
Can occupational therapists initiate the OASIS Start of Care for non-Medicare patients? It depends.
Private health insurance and Medicaid have their own rules about who can and cannot initiate the OASIS Start of Care and under what circumstances. The best thing to do in this scenario is to consult Medicaid and private insurer regulations. Keep in mind regulations may change with recent Medicare changes. So, if OTs previously couldn’t initiate and complete the OASIS Start of Care, it would be worth rechecking the guidelines.
Still no change? It sounds like a time for advocacy!
Advocating for occupational therapists to initiate the OASIS
Occupational therapy practitioners must take it upon themselves to educate home health agencies on the change in regulation. Remember that you may need to speak to multiple people and make multiple attempts before success.
Tips for educating your employer:
- Do your research.
- Be prepared to answer questions.
- Bring evidence such as this article, AOTA articles, or the CMS final CY 2022 rule change.
- Identify that the final rule is only for therapy-only cases.
- Identify why OT is the perfect profession to initiate the OASIS.
- experts in function
- experts in functional cognition
- skilled in assessing and incorporating multiple elements in an evaluation such as social determinants of health
- Identify how OT can improve accuracy on functional limitation reporting which directly impacts reimbursement under PDGM. Accurate scoring also helps agencies meet quality outcomes with accurate admit and discharge scoring.
What if your agency says no:
- Keep trying.
- Speak to someone else.
- Tell your coworkers and ask them to bring it up (strength in numbers).
- Take CEUs to build your own skills.
- Speak Up and Speak Often!
What if you or other OTs don’t want to do the OASIS?
- Discuss the pros and cons.
- Acknowledge income/pay concerns and discuss strategies to advocate for change.
- Identify concerns over low caseload due to other disciplines canceling OT orders – this won’t happen if OT opens the case.
- Offer to provide education on how to complete the OASIS.
This change is great news for occupational therapy in home health and helps ensure the longevity of OT in this setting. Some agencies have resisted hiring OTs full-time due to concerns that OTs cannot do all the necessary job elements as a PT can. However, we are now able to combat this assumption. Remember, if you don’t advocate for OT, who will
- AOTA – Next Step for OT Initiating the OASIS
- Amplify OT – What is PDGM in Home Health?
- Amplify OT – Is OT a Qualifying Service in Home Health?
- Amplify OT – Can OT still initiate the OASIS SOC when the PHE ends?
- AOTA – Next Steps for OASIS: Initiating and Completing the Comprehensive Assessment for Home Health
- CMS Finalized Home Health Prospective Payment System Update
- CMS Proposed HH PPS rule
- AOTA – What OTs Need to Know About Starting Medicare Home Health Cases, Part I
- AOTA – What OTs Need to Know About Starting Medicare Home Health Cases, Part II
- CMS Flexibilities under the Public Health Emergency (includes language on the temporary flexibility for the OASIS)