Do we need to transmit OASIS data on the non-Medicare/non-Medicaid, i.e., private pay patients?
The OASIS regulations and CMS policies currently in effect require that HHAs transmit data only on the Medicare/Medicaid patient who is receiving skilled care services, with the exception of maternity patients, patients under age 18, and those patients receiving aide care only or chore services. Currently, HHAs may submit OASIS data they collect on their non-Medicare and non-Medicaid patients receiving skilled services but only if it is in an unidentifiable (masked) format.
Current versions of the HAVEN software, i.e., HAVEN 4.0 and higher, will automatically mask the patient identifiers on those assessments where the pay source is identified as other than 1, 2, 3 or 4 at OASIS item M0150. However, it is not a requirement to submit OASIS data on the non-Medicare/non-Medicaid patient at this time. The requirement to submit OASIS data on the non-Medicare/non-Medicaid patient will be effective only when we publish a Federal Register notice to this effect. When it becomes effective, it will not be retroactive, i.e., we will not expect agencies to encode and transmit OASIS data on assessments completed prior to the effective date.