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Eyes Here: New OASIS Q&As (January 2022)

The Centers for Medicare & Medicaid Services (CMS) has released the latest OASIS Q&As, which provide guidance to OASIS questions received by their help desk from the fourth quarter of 2021. 

This set of Q&As includes a number of insights, such as updates on OASIS-E, clarifications on its data collection timeline, and guidelines on coding M and GG items on confusing and complex scenarios. From the set of 14 Q&As, we have picked some of the most notable ones.

Question 1: Will data collection for OASIS-E begin 1/1/2023? Or will it still begin on January 1st that is at least one full calendar year after the end of the COVID-19 Public Health Emergency? 

Answer: Based on the CY 2022 Home Health Final Rule, CMS finalized that OASIS-E data collection will begin with OASIS assessments with a M0090 date on or after January 1, 2023.

Question 2: Now that the OASIS-E data collection will begin 1/1/23 will CMS release an updated OASIS-E All Item Set instrument, given the changes as a result of rulemaking? If so, when can we expect it, and where will it be posted? 

Answer: As stated in the CY 2022 Home Health Final Rule, CMS will release a draft of the updated version of the OASIS instrument, OASIS-E, in early 2022. The updated draft dataset and the final OASIS-E dataset will be posted on the Home Health Quality Reporting Program OASIS Data Sets webpage (when available, date TBD) https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/OASIS-Data-Sets.

Please check the Home Health Quality Reporting Program Spotlight and Announcements webpage for updates.

Question 3: On December 31st, we recertified a patient, planning for a new 60-day certification period that started on January 3rd. Later in the day, on the 31st, the patient was admitted to the hospital and returned home on January 2nd. We completed a transfer (RFA 6) when they went to the hospital but now don’t know if we should complete a resumption of care (ROC) or complete a new Start of Care (SOC), since the inpatient stay didn’t extend into the new certification period. The patient’s insurance is traditional Medicare.

Answer: When completing the comprehensive assessment including OASIS upon the patient’s return home from the qualifying inpatient stay, if the M0090 – Date Assessment Completed is between days 56-60, complete an RFA 3 (ROC). If the M0090 – Date Assessment Completed is after day 60 (M0090 date falls in the subsequent certification period) complete an RFA 1 (SOC).

Question 7: A patient chooses not to fill a medication prescription, and therefore the ordered oral medication is not in the home and the patient is not taking it as prescribed. The assessing clinician determines the patient does not have a disorder that is contributing to their non-adherence. They are making a choice not to comply with physician’s orders, cognizant of the implications of that choice. How would M2020 – Management of Oral Medications be coded?

Answer: In situations where one or more medications that the patient is currently taking and are listed on the Plan of Care are not available to the patient, preventing the patient from being able to demonstrate their ability to manage oral or injectable medications, the assessing clinician could code using assessment strategies other than direct observation. The assessing clinician would rely on their assessment of the complexity of the patient’s overall drug regimen, as well as patient characteristics, including cognitive status, vision, strength, manual dexterity and general mobility, along with any other relevant barriers, and use clinical judgment to determine the patient’s current ability. In selecting a code, the clinician may use information gathered by report and/or observation, including details about when and how the patient accesses and administers their medications.

Question 11: Our agency is discharging a patient who will be admitted to a non-institutional hospice. After completing the discharge OASIS (M2420 – Discharge Disposition coded with response 3 -Patient transferred to a non-institutional hospice), the agency learns that the patient expired prior to being admitted to hospice. Does the clinician need to correct the M2420 code to response 1 -Patient remained in community (without formal assistive services)?

Answer: Discharge Disposition based on the information known at discharge regarding where the patient will reside, and the services the patient is expected to receive after discharge from the home health agency.

Elevating OASIS Documentation

It is helpful to regularly read through these quarterly Q&As and share it with clinicians, as they serve as an informative tool to improve documentation skills and judgment in answering OASIS questions. Completing the OASIS presents many challenges, requiring thorough analysis as it considers a lot of factors about a patient’s case. It is important that your QA team or provider is competent and proficient in analyzing different scenarios and proactive in recognizing opportunities to substantiate patient assessments. This will ultimately help you deliver quality patient care, optimize reimbursements, and build progress in every aspect of your home health operations.