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Q3 2021 OASIS Q&As: More OASIS Documentation Guidance

    The Centers for Medicare & Medicaid Services (CMS) just released their Q3 OASIS Q&As, providing more insights and guidance on OASIS documentation.

    The new set of Q&As sheds light on answering OASIS items on confusing and complex scenarios. Questions included were received directly by CMS help desks. Out of these, here are selected specific questions on OASIS M items with very informative answers:

    M1306 and M1311

    Question: I have a question about the current guidance that states: If a pressure ulcer/injury is surgically closed with a flap or graft, it should be considered a surgical wound and not a pressure ulcer/injury. If the flap or graft fails, it should still be considered a surgical wound until healed.

    Is this in reference to ANY point in time that the flap/graft fails? For example, if the area of flap/graft heals and has been 100% re-epithelialized for greater than 30 days and a patient subsequently develops a wound at the site of the original flap/graft, would it be considered failed surgical site or would it be considered a pressure ulcer/injury?

    Answer: If a pressure ulcer/injury was closed with a skin graft or flap, the surgical wound healed, and another pressure ulcer/injury forms in the same anatomical location due to pressure, then this would be considered a pressure ulcer/injury. Note it should be staged at the highest stage the pressure ulcer/injury was prior to closure unless currently presenting at a higher stage or unstageable.


    Question: Would a pacemaker or an implantable loop recording device be considered a surgical wound once the initial insertion site has been fully epithelialized for at least 30 days?

    Answer: The incisions created to implant a pacemaker or loop recording device are surgical wounds until re-epithelialization has been present for approximately 30 days at which time they become scars. At that point they would no longer be considered current surgical wounds, as neither the pacemaker nor the loop recording device, are a venous access device nor an infusion device.

    M1710 and M1720

    Question: I am looking for clarification on when to code response 4 for M1710 – When Confused and response 3 for M1720 – When Anxious. I know the look back period is the last 14 days however, there is no definition for “4 – Constantly” (for M1710) or “3 – All of the time” (for M1720). For “4 – Constantly” (M1710) or “3 – All the time” (M1720) to be marked, would the patient have to have been confused or anxious for the entire 14-day look back? Or would Constantly or All of the time apply if the patient was confused or anxious for a period of time shorter than the 14 day look back such as for an entire 24-hour period (constantly for at least one day)?

    Answer: The intent of M1710 – When Confused (Reported or Observed Within the Last 14 Days) is to identify the time of day or situations when the patient experienced confusion, if at all. M1710 response 4 – Constantly is indicated if a patient was confused at all times during the entire look back period of 14 days.


    Question: If a patient is not taking any high-risk medications at home, but goes to an outpatient oncology clinic for chemotherapy infusions how is M2010 – Patient/Caregiver High-Risk Drug Education answered?

    Answer: M2010 – Patient/Caregiver High-Risk Drug Education identifies if clinicians instructed the patient and/or caregiver about all of the patient’s high-risk medications. High-risk medications should be identified based on one or more authoritative sources and would be identified from medications included on the patient’s reconciled medication profile.

    Tips on Solving Complex OASIS Items

    Different scenarios may transpire for different patient cases, which makes answering OASIS items even more challenging. Thus, it is important for agencies to include regular case conferences in their QA workflow.

    Another surefire way of addressing this challenge is having a QA partner that has extensive experience in working with different agencies and encountering various cases. Aside from providing valuable insights, your QA provider should also be proactive in escalating and initiating discussions on complex cases. Beyond that, your QA provider should also contribute their inputs on how to resolve them.

    While there is no specific formula for answering OASIS items, especially the more tricky ones, there are ways to stay on top of it. A lot of components rely on clinical judgment, which should also be supported by CMS guidelines.

    Access the Q3 2021 OASIS Q&A here >
    Access all CMS Quarterly OASIS Q&A here >