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OIG Report Inadequate OASIS Documentation of Falls with Major Injury

    A recent report released by the Office of Inspector General (OIG) on September 5th revealed that home health agencies (HHAs) failed to properly document and report a significant number of fall incidents with major injuries, among Medicare patients.

    According to the report, 55% of major injuries resulting from falls were inaccurately documented in the OASIS. Furthermore, there were several instances where the OASIS was not transmitted at all. This underscores significant concerns about potential data submission noncompliance, thereby compromising the accuracy of information on falls leading to major injuries, which offer valuable insights into care effectiveness.

    Notably, home health agencies (HHAs) with the lowest Care Compare major injury fall rates report fewer falls than HHAs with higher Care Compare fall rates. This suggests that Care Compare does not provide accurate information about the frequency of falls among home health patients, thus impacting the perception of care quality provided by these agencies.

    To delve deeper into the issue, it is crucial to note that falls often occur when patients are supervised by caregivers when no HHA personnel is present. Hospitals may also fail to share accurate patient information due to a misunderstanding of HIPPAA or the lack of shareable data. As a reult, HHAs may complete the assessments for hospitalized patients with fall-related major injuries based on inaccurate information.

    The OIG recommended corrective action which CMS agreed to. One notable recommendation by OIG is for CMS to assess the potential benefits of implementing automated checks to identify inpatient hospital claims and encounters for home health patients. If these checks reveal that the required OASIS assessments haven’t been submitted promptly, CMS should notify home health agencies (HHAs). This proactive approach could potentially enhance the reporting rates for falls with major injuries.

    Documenting Falls Resulting in Injuries and Hospitalization

    With the OIG findings and recommendations for CMS, we can expect stricter scrutiny for HHAs for timely completion of OASIS and accurate completion of the OASIS assessments on injuries resulting from falls.

    If a patient is hospitalized for more than 24 hours (excluding standard tests), the HHA must complete an OASIS Transfer, which includes items J1800 and J1900 used to document incidents of falls and assess their severity.

    J1800 allows you to record that the patient experienced a fall. J1900 is used to document the severity of that fall. It details whether there was an injury related to the fall, if there was no injury, if there was an injury but not a major one, or if there was a major injury.

    The ‘Major Injury’ option on the OASIS includes bone fractures, joint dislocations, closed head injuries with altered consciousness, and subdural hematomas. These should be reported if they are the result of a fall. Additionally, any injury that resulted from a fall, not on the list of major injuries, should be recorded as Injury (Except Major) on the OASIS.

    HHAs must provide adequate OASIS training for staff, particularly focusing on fall-related incidents. Additionally, the Quality Assurance (QA) team should play a role in reviewing data accuracy to ensure the Transfer OASIS is complete and accurate, and that it’s submitted promptly to the OASIS database.