Home Health & Hospice Week

High-risk drug item confusion persists into the new year.

Assessing clinicians continue to struggle with new and modified items in OASIS-E without new help from Medicare.

For example: In the Centers for Medicare & Medicaid Services’ Jan. 11 Home Health Open Door Forum, a caller asked whether off-label uses should count toward a “yes” response for the “Indication Noted” column for N0415 (High-Risk Drug Classes: Use and Indication), but CMS staff on the call did not provide any guidance. Instead, they instructed home health agencies to submit questions to CMS via email (see HHHW, Vol. XXXII, No. 3).

In the first few weeks of OASIS-E, “medications have been a bit of a struggle for some data collectors in understanding the medication classes and indications for N0415,” agrees consulting firm OASIS Answers on its website.

Some providers and their representatives were hoping to see additional guidance for OASIS-E trouble spots like N0415 in the January edition of the Quarterly OASIS Questions and Answers. But that didn’t happen.

But instead, “it seemed that most of the responses repeated the guidance we already had without any additional information,” judges Cindy Krafft with K&K Health Care Solutions.

CMS does address N0145 in two of the 13 questions in the new set, but doesn’t furnish guidance on pressing issues such as the one voiced by the forum caller.

Silver lining: “In my experience, agencies are struggling with the flexibility in N0415 and are pushing CMS for more specifics,” Krafft tells AAPC. But “I am glad [CMS] didn’t provide it,” she says.

That’s because increased specificity often means loss of flexibility, Krafft acknowledges.

Meanwhile, the six-page Q&A set does address M0069 (Gender).

Question 9: “My question relates to a patient who self identifies as a gender different than that assigned at birth, but who has a disease that is inherent to the gender assigned at birth. Example: patient designated male at birth identifies as a female and has a diagnosis of benign prostatic hypertrophy (BPH). As the patient self-identifies as female, we report 2 — Female for M0069 — Gender. If we also list female as the gender on the claim, the claim is rejected because the diagnosis of BPH is not compatible with the female gender. How should we resolve this situation?”

Answer 9: “Regarding the accurate coding of the OASIS item M0069 — Gender, refer to the OASIS Guidance Manual and published Q&As, then use clinical judgment to complete required OASIS assessment items. The Guidance Manual states to interview the patient and/or caregiver. If the patient does not self-identify, referral information (including hospital or physician office clinical data), or observation and physical assessment may be used. Based on these resources, enter a response for patient’s gender in M0069. CMS has no additional guidance on how to complete this OASIS item.”

However, CMS continues, “OASIS is not intended to represent a comprehensive assessment in and of itself. HHAs are expected to incorporate OASIS items into their comprehensive assessment documentation and follow their own assessment policies and procedures regarding other items to include in their comprehensive assessments. This may include adding non-OASIS assessment items. At the CMS level, M0069 is not used in performing any gender specific procedure editing, and is not used for OASIS and claims matching functions. There are no instructions at the CMS level requiring the gender of the patient submitted on the claim to be populated from the gender response reported in M0069 of the OASIS.”

CMS adds, “More specific questions related to reporting gender codes on claims may be sent to the Home Health Medicare Administrative Contractor (MAC).”

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