Home Health & Hospice Week

In the most recent quarterly OASIS question-and-answer set issued this month, the Centers for Medicare & Medicaid Services includes important clarifications on some of the many questions home health agencies have about OASIS-E.

“All of these [latest Q&As] are important ones that must be shared with the data-collecting clinicians,” emphasizes OASIS expert Cindy Krafft with Kornetti & Krafft Health Care Solutions.

Avoid this pitfall: “I still see agencies keep this at the leadership/reviewer level and only disperse it via corrections to completed work,” Krafft laments. “That has never made sense to me,” she tells AAPC.

The time frame for assessment of nutritional approaches, special treatments, procedures, and high-risk medications is one critical topic that CMS addresses in the Q&As, highlights consultant J’non Griffin with SimiTree.

HHAs have been unsure of the timeframe, because K0520 - Nutritional Approaches Start of Care/Resumption of Care coding instructions in the OASIS-E Manual state only “Check all that apply during the time period under consideration for the SOC/ROC assessment.”

Likewise, O0110 - Special Treatments, Procedures, and Programs response-specific instructions in the manual instruct agencies to “apply during the time period under consideration for the SOC/ROC assessment.” And N0415 - High-Risk Drug Classes: Use and Indication instructions don’t specify a time frame either.

Now CMS has an answer for confused agencies.

Question 8: What is the look back or time period under consideration for the new OASIS items K0520 - Nutritional Approaches, N0415 - High-Risk Drug Classes: Use and Indication, and O0110 - Special Treatments, Procedures, and Programs? Is it the day of assessment, which may include medications, nutritional approaches, and/or treatments, procedures, or programs the patient may have taken/received in an inpatient facility before they were discharged home, or is coding just based on what is part of the current reconciled drug regimen and/or current care/treatment plan at the time of the assessment?

Answer 8: The general OASIS convention “Day of Assessment” which is defined as the 24 hours immediately preceding the home visit and the time spent by the clinician in the home does not apply to K0520 - Nutritional Approaches, N0415 - High-Risk Drug Classes: Use and Indication, and O0110 - Special Treatments, Procedures, Programs. These items are coded based on what is part of the patient’s current reconciled drug regimen and/or care/treatment plan during the SOC/ROC (or discharge) assessment.

In other words, when answering these items, “it is not the day of assessment (time of assessment and previous 24 hours), but actually what is part of the patient’s current plan of care/treatment,” Griffin underscores.

CMS also tackles the issue of how to code PICC lines when they are coming out at discharge, Griffin points out.

Question 14: 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 14: The intent of O0110 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.

CMS has clarified “for special procedures, to count the PICC line as current at DC, even if the PICC line was being discontinued/pulled on discharge,” Griffin reiterates.

Good news: Krafft is happy to see the quarterly Q&As move on to the next phase. “I find this round of Q&As much more helpful,” she praises. “You can tell they are now coming from ‘real life’ issues and not hypothetical ones, as seen by some of the questions asked before E went live,” she says.

Note: Links to quarterly Q&A sets are at https://qtso.cms.gov/reference-and-manuals/oasis-quarterly-q.