The Centers for Medicare & Medicaid Services made updates to the functional-level points thresholds in the CY 2022 final rule. CY 2020 claims data were used to update the functional points and functional impairment levels by the clinical group.
The update includes decreasing points on several of the OASIS scores and decreasing the threshold level for the level of impairment. This means that the same patient in 2021 that had a certain functioning level probably will have a lower score in 2022. With the new adjustments, it is going to take more functional disability to get to a ‘medium’ or ‘high.’
Functional Impairment Documentation Challenges
The functional impairment level is based on the responses to eight (8) OASIS-D1 items for activities of daily living (ADL) or commonly known as ‘M items’. Based on a point system, the responses from all M items determine the functional impairment level depending on the clinical category.
The accuracy of responses to the M items relies on the clinicians’ judgment and their patient assessment skills, which is often a challenge due to the complexity of M items. Each one involves different time considerations and requires different levels of assessment for different aspects of a patient’s ability to perform activities.
Addressing the Challenges
OASIS Documentation Knowledge
To ensure accuracy in the responses to the M items, significant OASIS education is needed. With the key factor being clinical judgment, clinicians must improve their patient assessment skills to accurately respond to the M items and decide which components are applicable to the patient.
OASIS QA review
This will significantly help improve and substantiate the clinician’s patient assessments on the M items. Having a second set of eyes dedicated to doing a comprehensive review of the OASIS and other relevant medical records would make a positive difference. On the other hand, QA review should not only be limited to checking the OASIS accuracy, but should also support clinician education by enabling them to improve their own patient assessment skills. This can be done by recording and tracking clinician documentation errors and/or areas for improvement.
Keeping Up with the Changes
Make sure your QA team or QA provider is knowledgeable of the changes in the functional level points from the CY 2022 final rule. Aside from checking the accuracy of M item responses, QA reviewers should proactively lookout for opportunities to improve M item scores, while still remaining compliant and mindful of the patient’s condition.
Having the right support and expertise for OASIS documentation will not only optimize reimbursements, but also ensure that patients receive the care they need and deserve.
CY 2022 Home Health Final Rule >