Home Health & Hospice Week

Switch: You aren't limited by the 2-day time frame, CMS clarifies.

A new set of quarterly questions-and-answers about OASIS is clearing up confusion regarding a troublesome topic - M0102 when the physician-ordered Resumption of Care is beyond 2 days after a facility discharge.

M01012 (Date of Physician-ordered Start of Care [Resumption of Care]) instructs assessing clinicians

"If the physician indicated a specific start of care (resumption of care) date when the patient was referred for home health services, record the date specified." The response options are to fill in a date, or check "NA - No specific SOC date ordered by physician."

Medicare's OASIS-C2 Guidance Manual tells clinicians "if the originally ordered Start of Care (SOC) is delayed due to the patient's condition or physician request (for example, extended hospitalization), then the date specified on the updated/revised order to start home care services would be considered the date of physician-ordered SOC/Resumption of Care (ROC). For example, a patient discharged home on May 15 but for whom the physician orders home care to begin May 20 for a specified order (for example,

PT or administration of a subcutaneous drug), would have a physician-ordered SOC date of May 20."

But the 2016 version of the manual told home health agencies that "because the State Operations Manual (SOM) requires a visit within 48 hours of ROC following hospitalization, mark 'N/A' if the physician orders a ROC date that extends beyond 2 calendar days of the inpatient facility discharge." The 2018 version of the manual omits that instruction.

This switch has caused some confusion, as evidenced by a recently released OASIS Q&A posted on the QTSO website.

Question: "Please clarify the changes, if any, to the M0102 as it relates to physician-ordered Resumption of Care dates," a provider asks.

Answer: "Prior to 1/13/18, if the physician-ordered ROC date was within 2 days of the patient being discharged from an inpatient facility, M0102 was coded with the physician-ordered ROC date.

Previously, if the physician-ordered ROC date was outside of the 2 days following discharge from an inpatient facility, then M0102 was coded as NA because there was no regulatory allowance for ROC date beyond 2 calendar days of facility discharge," the Centers for Medicare & Medicaid Services explains in the Q&A. "With the Home Health Conditions of Participation, effective 1/13/18, the assessment time frame for completing a Resumption of Care assessment was expanded to include allowance of a physician-ordered Resumption of Care date that is later than 2 days post-discharge. Effective 1/13/18, M0102 may be coded with the physician-ordered ROC date, even if the physician-ordered ROC date is later than 2 days post discharge."

Note: See the Q&As at https://qtso.cms.gov/download/hha/CMS_OAI_1st_Qtr_2018_QAs_April_2018_FINAL_508.pdf and the OASIS-C2 and the 2018 Guidance Manual at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/OASIS-C2-Guidance-Manual-Effective_1_1_18.pdf.