Another Way for Them to Take Your Money (Part 2)

Mary Carr at NAHC provides the following information regarding submitting the OASIS prior to claim that I want to share with you.
The edit is not intended to enforce the 30 day OASIS submission time frame.  The edit is checking  that an OASIS has been  submitted prior to the claim and that the HIPPS codes match. The edit is on claims with dates of service after April 1, 2017

When a claim is submitted the edit will look to see if the OASIS is in the system.

  • If the OASIS is present the claim will pay, regardless of whether or not  the OASIS was submitted within 30 days of the M0090 in accord with §484. 55.
  •  If the OASIS is not present, the edit will look to see if the date between M0090 and the date the claim was submitted is greater than 40 days. If these two conditions exist  the claim will deny.    


CMS is providing 40 days as a look back period since  agencies are provided  30 days to submit the OASIS and to accommodate any lag time that might occur when a claim and an OASIS  are submitted close to the 30 day time frame.    


The OASIS submission date changes in the QIES system with each OASIS modification and submission. However, since the edit is not enforcing the OASIS submission time frame requirement, modifications to the OASIS should not  cause a claim to deny, unless the correction requires an inactivation or deletion of the OASIS and the replacement OASIS is not entered prior to a claim submission.  There could be a small window where corrections to the OASIS could change the OASIS submission date to a date later than the claim submission date prior to the claim processing. We are checking with CMS for clarification on the implications for OASIS corrections and claim submissions.


At any rate, agencies should review and retain their validation reports to demonstrate that the OASIS associated with the claim was submitted prior to the claim.


Lisa Selman-Holman
Selman-Holman & Associates,LLC
CoDR–Coding Done Right

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