Don't let revamped guidelines cause confusion.
To help your staff get to know the feds' new OASIS guidance, keep this overview of revised items handy.
Tip: Many items haven't been changed. Rather, the Centers for Medicare & Medicaid Services is clarifying how items in the list below should be coded.
• M0060 (Zip code). CMS reminds agencies to supply patients' zip codes for Home Health Compare.
• M0063 (Medicare number). Don't enter an HMO identification number here. CMS gives additional guidance: "If the patient is a member of Medicare, another Medicare Advantage plan, or Medicare Part C, enter the Medicare number if available." If the number is not available, mark "NA - No Medicare."
• M0080 (Discipline of person completing assessment). Remember: The following groups aren't authorized to complete the comprehensive assessment: licensed practical nurses (LPNs), physical therapist assistants, certified occupational therapy assistants, medical social workers and home health aides.
• M0100 (Reason for assessment). CMS reminds providers to indicate Response 1 whenever an initial HIPPS code is needed for a home health resource group, whether or not the patient will be receiving ongoing services.
• M0150 (Current payment source). This item now expressly limits the payment source(s) selected to those paying for services included on the plan of care that you will bill.
• M0200 (Medical treatment change). Note that a physician appointment alone or a referral for home health services does not qualify as a medial treatment regimen change. In addition, remember that any change falling on the day of the assessment does not fall within the 14-day period.
• M0230/240 and M0254 (Diagnoses). The secondary diagnosis includes "all conditions that co-existed at the time the plan of care was established, or developed subsequently, or affect the treatment of care," reminds CMS. Such conditions should include not only those actively addressed in the plan of care but also any co-morbidity affecting the patent's responsiveness to treatment and prognosis.
Red flag: CMS erroneously included a "severity rating" for this item. Home health agencies and software vendors should ignore the severity ratings when implementing other Chapter 8 changes.
• M0250 (Therapies). Be careful when considering Response 1, In Intravenous or Infusion Therapy. A new instruction advises home health agencies not to select that response if there are orders for an IV infusion to be given when specific parameters are present but the parameters are not met on the day of the assessment. Response 1 is also inappropriate if the patient is receiving peritoneal dialysis or home dialysis.
• M0420 (Pain frequency). Note this new definition: Pain interfering with activity is described in detail as pain "that results in activities being performed less often than desired, results in the need for additional assistance, or results in taking more time to complete."
• M0430 (Intractable pain). CMS has added these three criteria for defining "intractable pain:" not easily relieved, present at least daily, and affects the patient's quality of life.
• M0445, M0450, M0464 (Pressure ulcer). CMS has updated its instructions and assessment strategies for staging pressure ulcers that require reverse staging of Stage 1 and Stage 2. The new guidance is based on the 2004 guidance from the National Pressure Ulcer Advisory Panel. For more information, go to www.npuap.org/about.html.
• M0482 (Surgical wound). A wound that has completely healed (has become a scar) is no longer a surgical wound, advises CMS in its revised instructions. New instructions also specify that "cataract surgery of the eye or a gynecological surgical procedure via a vaginal approach does not create a surgical wound for this item," nor do debridement or placement of a skin graft create a surgical wound.
Special circumstance: A "take-down" procedure of a previous ostomy produces both a wound/lesion (M0440) and a surgical wound.
• M0488 (Status of surgical wound). A "healing ridge" should no longer be used to determine the status of a surgical wound, according to CMS' new instructions.
• M0490 (Short of breath). If you are assessing shortness of breath in chair- and bed-bound patient, consider when he performs activities of daily living (ADLs), advises CMS.
• M0640 through M0820 (ADLs and IADLs). Note that the manual's general instruction to "choose the response describing the patient's ability more than 50 percent of the time" may apply to these OASIS items, as appropriate.
• M0680 (Toileting). If a patient can get to and from the toilet but uses the commode at night for convenience, use Response 1 (Able to get to and from the toilet independently with or without a device).
• M0690 (Transferring). New information advises that "taking extra time or pushing up with both arms can help ensure the patient's stability and safety during the transfer process, but they do not mean that the patient is not independent."
• M0700 (Ambulation/locomotion). When responding to this item, consider any medical restrictions. Key question you should ask: What can the patient do safely?
• M0710 (Feeding or eating). The feds have expanded instructions to include a list of examples of "meal set-up" activities. These include "activities such as mashing a potato, cutting up meat/vegetables when served, pouring milk on cereal, opening a milk carton, adding sugar to coffee or tea, arranging the food on the plate for ease of access, etc., all of which are special adaptations of the meal for the patient."
• M0720 (Meal planning and preparation). CMS reminds agencies to consider a patient's dietary requirements as an assessment strategy.
• M0780 (Oral medications). CMS clarifies two points regarding medication management. First, a patient who sets up her own "planner device" and is able to take the correct medication in the correct dosage at the correct time is considered "independent in administration." However, if another person must create a list or set up a planner device, you should select Response 1 (Able to take medication[s] at the correct times if ...).
• M0790 (Inhalant/mist medications). Oxygen should be considered an inhalant medication, CMS clarifies.
• M0825 (Therapy need). Assessment strategies allow for the use of "yes" or "no" responses when therapy threshold information is needed to establish a case-mix weight for payers that are not Medicare fee-for-service.
• M0830 (Emergent care). A patient held in an emergency room for observation, regardless of how long, is considered to have received emergent care. Persons who die in an emergency room, however, are under the care of the emergency room, not the home health agency. Therefore, a "transfer assessment" should be completed, not a "death at home" assessment.
Source: National Association for Home Care & Hospice