Home Health & Hospice Week

CMS issues clarifications on confusing OASIS questions.

Under the coming prospective payment system revisions, how accurately you answer OASIS will affect your reimbursement rate more than ever.

The Centers for Medicare & Medicaid Services Survey and Certification Group recently provided extensive answers to 36 questions from the OASIS Certificate and Competency Board.

Among the questions-and-answers were ones regarding these case mix items: Question: Do you time continence for M0520?

This OASIS item will be new to case mix under revised PPS, accounting for a whopping 17 points in the Non-Routine Supplies (NRS) payment add-on. That could take the episode from a NRS severity level 0 at $12.96 as proposed, to level 2 at $109.48. It could also bump it from a level 3 ($215.17) to a level 4 ($367.34).

Answer: There is no specific time a patient must stay continent to no longer be incontinent. You must use clinical judgment and current clinical guidelines to decide if the cause of a patient's incontinence is resolved, CMS says in Question 23. Question: Does an adapted home setting affect M0650/M0660?

CMS will use this OASIS item on dressing to calculate PPS' functional domain score (see Eli's HCW, Vol. XVI, No. 22). It can garner up to six functional domain points for an episode.

Answer: If a patient can safely access clothes and put them on and remove them, you can consider him independent in dressing, CMS says in Question 25. This is true even if he is in a wheelchair and has specially adapted closets and drawers to simplify the process. Take All OASIS Items Seriously Even if an OASIS item doesn't directly impact PPS payment, it's still important to answer it as accurately as possible for outcomes, medical review, billing and data integrity reasons, experts emphasize.

A year after the last major OASIS Q&A clarifications, clinicians continue to find many OASIS M0 items unclear. Sequence of visits, hospitalizations around crucial recertification dates and emergent care issues continue to draw queries. More highlights of the new Q&As include: • Who visits first? Agencies still are confused about sequence of visits when both nursing and therapy are ordered at start of care (SOC). "A registered nurse must conduct the initial assessment unless it is a therapy only case." CMS instructs. So when the physician orders nursing at SOC, the RN must be the first person to see the patient and complete the initial assessment, Question 2 clarifies.

The initial assessment determines the patient's immediate care and support needs and whether the patient is eligible for the Medicare home health benefit. It is not the same as the comprehensive assessment that includes the OASIS, CMS says.

Beginning therapy need not wait for the comprehensive assessment, only the initial one, the answer states. "If [...]