The Centers for Medicare & Medicaid Services (CMS) has recently published a new set of quarterly OASIS Q&As. It includes questions received by the CMS help desks from the first quarter of this year, following the implementation of the new OASIS-E. These Q&As offer valuable guidance on addressing specific OASIS-E questions in complex situations, clarifying the inclusion of new OASIS items in risk models, and the latest exclusions from quality reporting.
We have selected some Q&As from the set that we believe to be the most helpful.
New Risk Models
Question: Are the new items that were added to the OASIS-E instrument being used in the new risk models that took effect 1/1/2023?
Answer: To include new items in risk models, CMS first needs to analyze the data submitted for those items. As data collection for OASIS-E began January 1, 2023, the items new to OASIS-E are not used in these new risk models but will be evaluated and considered for use in future risk models. However, as CMS was able to map responses available from OASIS-E item D0150 – Patient Mood Interview (PHQ-2 to 9) to the responses available from OASIS-D1 item M1730 – Depression Screening, D0150 is used in the new risk models that took effect January 1, 2023.
Quality Reporting Exclusion
Question: What assessment-based quality measures exclude patients who are transferred or discharged from home health to hospice?
Answer: Patients who were transferred to an inpatient hospice or discharged to a non-institutional hospice (on or after January 1, 2023) are excluded from the calculation of the following OASIS-based quality measures:
- Improvement in Ambulation/Locomotion
- Improvement in Bathing
- Improvement in Bed Transferring
- Improvement in Toilet Transferring
- Improvement in Lower Body Dressing
- Improvement in Upper Body Dressing
- Improvement in Management of Oral Medications
- Improvement in Bowel Incontinence
- Improvement in Confusion Frequency
- Improvement in Dyspnea
- Discharged to Community
These hospice exclusions apply to quality episodes with a M0906 Discharge/Transfer/Death Date of 1/1/2023 or later:
- That end in a transfer to an inpatient hospice (M0100 Reason for assessment – RFA 6 or 7 Transferred), and M2410 – Inpatient Facility response is 4 – Hospice, OR
- That end in a discharge to a non-institutional (home) hospice (M0100 Reason for assessment – RFA 9 Discharge from Agency), and M2420 – Discharge Disposition is response 3 – Patient transferred to a non-institutional hospice.
Question: Please clarify when the entire Patient Mood Interview should be completed for D0150 – Patient Mood Interview (PHQ-2 to 9). The instruction in the OASIS-E Guidance Manual appears to conflict with the language in the D0150 item.
Answer: At times CMS provides new or refined instruction that supersedes previously published guidance. In such cases, use the most recent guidance. Related to the Patient Mood Interview, please disregard the statement in the OASIS item that states “If either D0150A2 or D0150B2 is coded 2 or 3, CONTINUE asking the questions below. If not, END the PHQ interview”. This statement is outdated due to refinements in OASIS guidance.
Please use the instruction found in the Response-Specific Instructions for D0150 in the OASIS-E Guidance Manual, which reflects the most recent guidance. As stated in the manual, whether or not further evaluation of a patient’s mood is needed depends on the patient’s responses to the PHQ-2 (D0150A and D0150B). If both D0150A1 and D0150B1 are coded 9, OR, both D0150A2 and D0150B2 are coded 0 or 1, END the PHQ interview; otherwise continue. For all other scenarios proceed to ask the remaining seven questions (D0150C to D0150I) of the PHQ-9 and complete D0160, Total Severity Score.
Question: Please provide guidance on the following scenario. A patient is admitted to a home health agency and then, during the assessment timeframe, goes to the Emergency Department (ED) and receives a one-time dose of a medication that is classified as a medication in the list of high-risk medication for N0415 – High-Risk Drug Classes: Use and Indication. If the Start of Care assessment was not completed until after the patient returned from the ED should the medication that was received in the ED be considered when coding N0415?
Answer: The intent of N0415 – High-Risk Drug Classes: Use and Indication is to record whether the patient is taking any prescribed medications in the specified drug classes and whether the patientspecific indication was noted for all medications in the drug class.
Code any medication that is used by any route in any setting (e.g., at home, in a hospital emergency room, at physician office or clinic) while a patient of the home health agency that is also part of a patient’s current reconciled drug regimen, even if it was not taken at the time of assessment.
Question: We know that we code O0110 – Special Treatments, Procedures, and Programs based on what is part of the current care/treatment plan at the time of the assessment. Can CMS provide further clarification on how to code O0110O1 – IV Access and O0110O4 – IV Access; Central if a PICC line is being pulled during the discharge assessment?
Answer: The intent of O0110 – Special Treatments, Procedures, and Programs is to identify any special treatments, procedures, and programs that apply to the patient. Check all treatments, programs and procedures that are part of the patient’s current care/treatment plan at the time of assessment, even if not used during the time of assessment for SOC/ROC (or discharge). This includes a PICC line that is being discontinued at the time of the assessment
Enhancing OASIS Data
Completing the OASIS form can be challenging due to various factors that require a thorough analysis and understanding of a patient’s case. Reviewing the quarterly CMS Q&As can improve one’s ability to answer assessment items in the OASIS.
To help ensure OASIS accuracy, your QA team or provider must also be proficient in evaluating unique patient cases and identifying areas for improving OASIS item responses. This will further promote patient-centered care, improve outcomes, and optimize reimbursements.