Home Health & Hospice Week

Plus: Where’s the finalized OASIS-E form?

If you were hoping a thorough intake process would save your OASIS staff some time, that may not always be the case. So indicates a question-and-answer in the latest quarterly OASIS Q&As, which largely address the OASIS-E tool that takes effect Jan. 1.

Question: “Can information collected prior to Start of Care/Resumption of Care be used to complete the new OASIS items such [as] A1005 — Ethnicity, A1010 — Race, A1110 — Language, A1250 — Transportation, B1300 — Health Literacy, and D0700 — Social Isolation?” a home health agency asks the Centers for Medicare & Medicaid Services in the set released Oct. 18.

Answer: “If information used to complete the OASIS is gathered prior to the patient’s admission, this information should be verified and coded following applicable coding guidance, during an assessment that occurs during the SOC/ROC time period,” CMS responds. “An agency’s software may not ‘answer’ or ‘generate’ the OASIS response for the assessing clinician,” CMS directs.

“Please note that based on coding guidance, the medical record should not be used as the data source for coding Health Literacy and Social Isolation,” CMS adds. And “the medical record should not be used as the data source for coding Ethnicity, Race, Language, and Transportation unless the patient and proxy are unable to respond during each specific assessment period during the SOC/ROC or discharge assessment time periods.”

In other words, CMS is saying “an EMR couldn’t automatically mark something,” explains J’non Griffin with SimiTree Healthcare Consulting.

For example: Take preferred language, Griffin offers. “If it is put in intake, then the clinician must verify all that information,” she tells AAPC.

Griffin laments that the five-page Q&A set doesn’t have “more substance,” she continues. With the Jan. 1 implementation date looming ever closer, HHAs have some crucial points they’d like clarified, including questions about:

• N0415 — High-Risk Drug Classes: Use and Indication. “What kind of documentation can [providers] take? Does it have to be directly from a provider? What if they have a med list from a nursing home and that list has indications for use?” Griffin lists. “There is no clear guidance on that.”

CMS punts on the topic in a Q&A in the Oct. 18 set. It tells agencies to “code medications according to the medication’s therapeutic category and/or pharmacological classification,” but notes that “CMS does not specify a source for identifying the therapeutic category and/or pharmacological classification.”

• B1300 — Health literacy. “Health literacy is a bit confusing,” Griffin says, noting that she’s “not sure if everyone understands that.” (See sidebar, p. 295 flipbook, for related issues with self-reporting.)
• COPs. Providers are asking Griffin about how the new OASIS data set “may or may not interact with surveyors and the [Conditions of Participation],” she reports.
• Finalized tool. Finally, “people are still anxiously awaiting the final version of the OASIS,” Griffin observes. CMS issued the latest draft tool back in May, and has yet to issue the final Office of Management and Budget-approved version with only about 10 weeks left until it goes live.

Note: A link to the October Q&As is at https://qtso.cms.gov/reference-and-manuals/oasis-quarterly-q.