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Limited Oversight of Home Health Agency OASIS Data


Outcome and Assessment Information Set (OASIS) data are the basis for home health payment, quality measures, and consumer information on the Home Health Compare Web site. Timely and accurate submission of these data is vital for home health agencies' (HHAs) efforts to improve quality and for consumers researching HHAs. In addition, State survey staff use OASIS data in the survey and certification of HHAs, which ensures that HHAs are meeting all Conditions of Participation required by Medicare.


We surveyed all States regarding their responsibilities for OASIS data. We conducted structured interviews with CMS staff. We also obtained all home health Part A claims and OASIS records for 2009 to determine which submitted claims were missing a required OASIS record. Finally, we obtained a list of all HHAs that CMS penalized from 2007 to 2010 by assessing the 2-percent payment reduction.


HHAs did not meet all Federal reporting requirements. They did not submit required OASIS data for 392,180 (6 percent) of claims in 2009, which represented over $1 billion in Medicare payments. Only 199 HHAs were penalized by CMS with the 2-percent payment reduction from 2007 through 2010. Furthermore, HHAs submitted 15 percent of OASIS datasets late. Some States provided training and technical support to HHAs and almost all restricted access to OASIS data. States conducted limited data analysis and review of the accuracy of OASIS data. Finally, CMS did not ensure the accuracy or completeness of OASIS data and did not validate States' processes for monitoring submitted OASIS data.


Our report made three recommendations to CMS. First, identify all HHAs that failed to submit OASIS data and apply the 2-percent payment reduction to them. Second, establish and implement enforcement actions for HHAs that submit OASIS data after the 30-day deadline. Third, develop clear guidelines that delineate expectations for States regarding timely and accurate OASIS data. CMS concurred with our first recommendation and did not concur with our second or third recommendation.