Home Health & Hospice Week

New quarterly Q&As shed light on tricky scenarios.

Smart home health agencies will heed a warning in the feds’ latest OASIS guidance.

The Centers for Medicare & Medicaid Services issued its quarterly OASIS questions-and-answers on April 16. The six-question set addresses a number of topics, including whether and how HHAs should take advice from outside parties.

Question 1: A third-party external auditor consistently states that our OASIS functional status items are “underscored” and recommends changing the responses to the OASIS items. Is the assessing clinician required to accept the auditor’s recommendations?

Answer 1: While a home health agency may use third party external auditors to review OASIS coding and make recommendations, the assessing clinician is responsible for determining OASIS coding based on their assessment.

Each OASIS item should be considered individually and coded based on the guidance provided for that item.

When a potential inconsistency is identified within the assessment timeframe (including inconsistencies identified by a vendor/consultant/third-party reviewer), the assessing clinician may consider available input from these other sources and determine if any revisions to OASIS item responses is warranted, within the assessment timeframe and consistent with OASIS guidance.

Other questions address inadvertently omitted Symptom Control Ratings for M1021/M1023 (Primary Diagnosis/ Other Diagnoses); coding of falls caused by seizures (M1033, J1800, J1900); and coding scenarios for M1830 (Bathing), GG0100A (Prior Level of Functioning: Everyday Activities), and M2001 (Drug Regimen Review).

Note: The three-page Q&A set is at https://qtso.cms.gov/system/files/qtso/CMS_OAI_1st Qtr_2024_QAs_April_2024_final.pdf.