Home Health & Hospice Week

Tip: Avoid a CoP violation with CMS’s latest advice.

A newly released OASIS question-and-answer about completing a Discharge OASIS in the absence of a qualified clinician who has seen the patient might make your life more difficult.

Question: We have a situation with an unexpected discharge. The nurse who was the last qualified clinician to see the patient is out on maternity leave. How do we complete the OASIS discharge?

CMS’s Answer: In the case of an unplanned or unexpected discharge (an end of home care where no in-home visit can be made), the last qualified clinician who saw the patient may complete the discharge comprehensive assessment document based on information from his/her last visit. The assessing clinician may supplement the OASIS items on the discharge assessment with information documented from patient visits by other agency staff that occurred in the last 5 days that the patient received visits from the agency prior to the unexpected discharge. The “last 5 days that the patient received visits” are defined as the date of the last patient visit, plus the four preceding calendar days. In your situation, the last qualified clinician who saw the patient is not available. Follow these steps:

1. If possible, send another clinician out to visit the patient and perform the Discharge comprehensive assessment visit.

2. If not possible to visit the patient, look back in the notes to find another qualified clinician who saw the patient (preferably as close to the time of discharge as possible), and who could complete the discharge comprehensive assessment based on their last visit. The assessing clinician may supplement the discharge assessment with information documented from patient visits by other agency staff that occurred in the last 5 days that the patient received visits from the agency prior to the unexpected discharge.

3. If the clinician on leave was the only qualified clinician to see the patient and it is impossible to make an additional visit to the patient, it may not be possible to complete a Discharge comprehensive assessment. The Discharge comprehensive assessment requires an in-person patient encounter and assessment from a qualified clinician per the Medicare CoP 484.55 Comprehensive assessment. A supervisor or other agency clinician who has not visited the patient cannot complete a discharge comprehensive assessment compliantly using only information documented from patient visits by other agency staff that occurred in the last 5 days that the patient received visits from the agency prior to the unexpected discharge.

This “very informative” Q&A is “very clear,” praises Diane Magrady, compliance lead with Morton Grove, Illinois-based Pragma-IT, creator of the therapyBOSS therapy documentation software solution. CMS’s guidance boils down to having another clinician go out to do a visit if possible, having another qualified clinician who has seen the patient complete the assessment, or not completing the assessment at all, Magrady tells Eli.

“It may be surprising to some agencies to learn that that clinicians — including clinical management — who have not seen the patient are not allowed to complete the assessment, even if their responses are based on information in the medical record,” Magrady says.

Note: The Q&As are at https://qtso.cms.gov/download/hha/CMS_OAI_2nd_Qtr_2018_QAs_July_2018_FINAL_508.pdf.