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OASIS Answers - Wednesday, July 25, 2012

CMS National OASIS-C1 Provider Training Webinar POSTPONED

OASIS Answers - Tuesday, April 15, 2014

The Centers for Medicare & Medicaid Services (CMS) is examining the implications of the ICD-10 provision in the recently enacted Protecting Access to Medicare Act of 2014 and will provide guidance to providers and other stakeholders soon on the implementation of OASIS-C1. Until that time, the Division of Continuing Care Providers, in conjunction with the CMS training department, will not be providing the OASIS-C1 implementation webinar originally scheduled for April 30, 2014. Once CMS makes a decision about OASIS-C1, it will be determined if it is appropriate to reschedule the webinar.


Patricia Sevast, RN, Nurse Consultant, CMS Survey & Certification Group

Linda Krulish, PT MHS COS-C, President, OASIS Answers, Inc.

Deborah Chisholm, RN, BSN, CPHQ, COS-C, Director of Educational Programs, OASIS Answers, Inc.



OASIS Answers still has limited space available for our Quarterly OASIS Q&A Update Teleconference, scheduled for tomorrow, April 16 from 1 pm to 2:30 pm (Eastern). Register now to reserve your spot!

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OASIS Answers - Tuesday, April 01, 2014

Today is April 1st, but this is no April Fool's joke... Last night, at 6:59 pm Eastern Time, the Senate passed a bill that will delay the implementation of ICD-10 until at least October 1, 2015. The main focus of the bill, known as the Medicare "Doc Fix Bill", was to provide a temporary fix to a 24% physician Medicare payment reduction, which was slated to go into effect today.   Embedded in the bill was a relatively brief, seven line portion delaying ICD-10. All providers, including home health, have been preparing for a timeline that had implementation going into effect six months from today. 

The impact of the ICD-10 delay on home health providers is wide spread. From education and training to documentation, electronic medical records, billing, auditing, quality reporting and compliance, all stakeholders will be regrouping to determine how to proceed. The one thing we DO know is that we don’t have all the facts yet.

What now?
So what’s a prudent course of action to take, while the "powers that be" outline a game plan?   Just keep swimming… Just keep swimming…  Keep moving forward.  Why stop preparing?  ICD-10 has only been postponed.  It has not been abandoned.  Coders who have attended recent OAI ICD-10 coding workshops have been enthusiastic but have also have realized ICD-10 is a big change. Many voiced that they wished they had more time to get used to the new code set.  One of the biggest concerns about this transition has always been how it will impact productivity, and therefore costs.  Going ahead with ICD-10 training will allow coders more time to prepare and gain proficiency, minimizing negative impacts of the transition.

Another reason to continue with ICD-10 training is this:  An unanticipated benefit of ICD-10 training is that it makes coders better at assigning ICD-9 codes as well.  How does that work?  It’s because there are far more similarities than differences between the two coding systems.  The Four Cooperating Parties who are in charge of both ICD-9 & ICD-10 in this country have focused most of their efforts the past several years getting ICD-10 ready for use.  They have not developed coding changes or annual updates to the coding rules for ICD-9.  Therefore many of the rules and explanations that are provided in ICD-10 training answer questions coders have about ICD-9.

As we moved closer to what we all thought was the implementation deadline, one very popular strategy that has emerged is the concept of dual coding.  Software vendors have been doing end-to-end testing of data transmission.  In order to do that, they also had to make sure their software could recognize the difference between the two code sets during the transition phase.  Since this capability exists, there is a grassroots movement to request the ability to report both types of codes on documentation – not as a requirement but as an option.  This would allow us to continue practicing and working out any unanticipated glitches before we "go live".

Clearly there are a lot of discussions to be had and issues to be settled.  In the meantime, one thing is certain - coders still need training.  Since many seasoned ICD-9 coders left our ranks because they weren’t interested in “enduring one more change”, a large influx of brand new coders are making the coding decisions in our agencies and for our industry. These coders are desperate for education.  As we have surveyed attendees at our recent coding classes, almost one-third of all participants have had NO previous coding instruction at all, yet they are assigning ICD-9 codes in patients’ medical records on a daily basis.

Remember, coding is more than numbers on documents.  Coding contributes to our risk adjustment and reimbursement.  When we are asked if what we are doing with our patients is “reasonable & medically necessary,” the answer must tie back to what is wrong with the patient.  We can provide all the best clinical practices with the right mix of clinicians but if the case is coded incorrectly it can appear as though we don’t know what we’re doing or that the care we're providing is unnecessary.  

So the bottom line is that there is a lot riding on getting these codes right. Accurate coding is provided by skilled professionals who need and deserve proper training.  If you’ve started training in ICD-10, stay the course. Allow your coders to practice and gain proficiency between now and its eventual implementation date.  If you have new coders who are assigning ICD-9 codes, make sure that they have the tools they need to assign those codes properly.  It looks like we have at least 18 months until ICD-10 is implemented.  That’s far too long to let inexperienced coders fumble around assigning ICD-9 codes. Don’t drop ICD-10 training but instead, based on the needs of the coders in your agency, consider adding ICD-9 training back into the mix to support your newer coders.  Dual coding is a great idea, but requires skilled coders who are well versed in both.  Academia continues to offer “dual track coding” and maybe it’s time to take a lesson from them.  Don’t drop ICD-10 training.  Consider adding ICD-9 training back in the mix.

Home health’s next logical question: What about OASIS-C1?
A significant related issue is how the ICD-10 delay will impact the transition to OASIS-C1, which was scheduled to occur simultaneously with the transition to ICD-10. In fact, the transition from ICD-9 to ICD-10 was the impetus for CMS scheduling a revision to the OASIS data set, updating item language, instructions, and expanding spaces available to allow the seven-digit alpha-numeric reporting required by the ICD-10 code set.  

The impact to OASIS-C1 remains to be seen, but in continuing with our long-standing corporate philosophy, OASIS Answers, Inc. will collaborate with CMS and other critical stakeholders to contribute to a plan and create strategies that effectively support home health providers in ongoing competency and compliance with home health coding and OASIS data collection. We will continue to provide ICD-10 training, because we believe that doing so will provide agencies the opportunity to not only transition to ICD-10 with competency and confidence, but will also improve compliance with ICD-9, for its remaining months of use.

For those seeking coding training, we will be available to meet those needs through our proven educational programs for both ICD-9 and ICD-10. We will continue to educate thousands through our Blueprint for OASIS Accuracy workshops, integrating OASIS-C1 training into the curriculum as relevant guidance is available, and in a timeline that will effectively meet the provider needs.

Stay tuned and, in the meanwhile, remember that coding and OASIS data collection are ongoing requirements that require diligent effort to achieve required accuracy. And regular access to effective training will improve competency in ICD-9 AND ICD-10, only building a better foundation for home health coders when ICD-10 finally "hits".

Those who have and continue to invest time and energy into gaining competency in OASIS-C will reap a major payoff of what, to them, will be an uneventful transition to OASIS-C1. Delayed, or not.

Keep Calm, and Code on... We’ll keep you informed.

Linda Krulish PT MHS COS-C
OASIS Answers, Inc.
Sparkle Sparks, PT, MPT, COS-C, HCS-D
AHIMA Approved ICD-10-CM Coding Instructor
Senior Associate Consultant, OASIS Answers, Inc.

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CMS to offer National OASIS-C1 Provider Training Webinar

OASIS Answers - Tuesday, March 25, 2014

On April 30, 2014,  2:00-3:30 pm EST, the Survey and Certification Group is sponsoring a webinar on “OASIS-C1”.  The topics of this webinar include:

  • The new OASIS-C1 data set and its implementation, scheduled for October 1, 2014;

  • Types of changes made to the data set;

  • OASIS-C1 Guidance Manual changes; and

  • OASIS Q&As update.


Patricia Sevast, RN, Nurse Consultant, CMS Survey & Certification Group

Linda Krulish, PT MHS COS-C, President, OASIS Answers, Inc.

Deborah Chisholm, RN, BSN, CPHQ, COS-C, Director of Educational Programs, OASIS Answers, Inc.


This webinar is intended for all State Survey Agencies and Regional Office staff, as well as Home Health Agency providers.

Questions related to OASIS-C1 and its guidance should be submitted prior to and following the webinar to the National CMS OASIS mailbox at: 

CMS has reserved a total of 1,000 lines for this webinar.  All participants will be in the same queue, so you are encouraged to call in up to 30 minutes ahead of start time. If you are not able to get in, the webinar will be archived within 3-4 weeks after the live presentation.

Webinar materials will be forthcoming prior to the webinar and posted at:

  1. On the day of the webinar go directly to

  2. From the Adobe Connect Meeting window, type your name in the “Guest Box.” 

  3. Press “Enter Room” to access the webinar.

  4. Dial into audio bridge number, (877) 251-0301 (Conference ID:  9431125) to hear the audio portion of the Webinar.

For webinar technical questions contact Etolia Biggs at, 410-786-8664.

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