OASIS Validation Audits Cancelled

The Centers for Medicare & Medicaid Services (CMS) has suspended the Outcome and Assessment Information Set (OASIS) submission audits conducted in the New England states. CMS has instructed Strategic Health Solutions (SHS) to begin issuing record request cancellation letters to the providers from whom they have requested records. The supplemental medical review contractor, SHS, has been forced to withdraw the OASIS validation audits, which is a tremendous relief to New England agencies.

Several New Hampshire agencies were parties to this audit nightmare and they had lots of company as agencies throughout New England got caught in an OASIS-related recoupment trap. At issue was how to prove that 2010 OASIS assessments submitted to state OASIS offices were both accurate and timely.

CMS’ Supplemental Medical Review Contractor (SMRC) Strategic Health Solutions (SHS) had sent additional documentation requests (ADRs) for supporting information on more than 20 issues related to 2010 claims, including “proof of OASIS submission and acceptance by the state.” One mystery, according to Mary Carr, associate director for regulatory affairs for the National Association for Home Care & Hospice (NAHC), is what instructions CMS gave SHS regarding its follow-up to the OIG findings.

The ADRs appeared to be in response to an HHS Office of Inspector General (OIG) study that found Medicare contractors shouldn’t have paid many of the 2010 claims submitted in Connecticut, Rhode Island, Massachusetts, Vermont, New Hampshire and Maine. The report claims the OASIS assessments weren’t filed on time or they had submission errors.

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