Home Health & Hospice Week

You've got the green light to use new NPUAP guidelines.

Home health agencies caught in limbo on staging of severe pressure ulcers are getting relief.

In a surprise reversal, the Centers for Medicare & Medicaid Services now says you may stage a pressure ulcer for M0450 (Current number of pressure ulcers at each stage) and M0460 (Stage of most problematic [observable] pressure ulcer) if eschar or slough partly obscures the ulcer, but bone is visible.

“You can stage a pressure ulcer when some eschar or slough is present as long as the wound bed is visible and you can see the extent of tissue involved,” says a new CMS question and answer contained in a July 10 letter from Patricia Sevast of CMS’ Survey and Certification Group to the OASIS Certificate and Competency Board.

CMS makes the about-face in Q&A number seven in the document posted to OCCB’s Web site. The retraction of the previous CMS OCCB Q&A number 24, dated July 2006, is in response to the February 2007 update to the National Pressure Ulcer Advisory Panel’s guidance on pressure ulcer staging, CMS says.

Bottom line: The change in instructions should allow agencies to receive more money for patients with severe pressure ulcers, observers expect. CMS At Odds With WOCN, NPUAP Background: In the July 2006 Q&A, CMS stated that “any pressure ulcer with any amount of eschar or slough present, even an ulcer with bone visible, would be considered non-observable and therefore could not be staged.”

The July 2006 Wound Ostomy Continence Nurses guidance on OASIS skin and wound M0 items did not specifically support that view. It said that “a pressure ulcer cannot be accurately staged until the deepest viable tissue layer is visible; this means that wounds covered with eschar and/or slough cannot be staged and should be documented as non-observable.”

Then in February the NPUAP released its guidance stating that in a Stage III pressure ulcer “slough may be present but does not obscure the depth of the tissue loss.” In a Stage IV pressure ulcer “slough or eschar may be present on some parts of the wound bed” (see Eli’s HCW, Vol. XVI, No. 9). Since then, CMS has been reconsidering its response.

Resource: The 19 new CMS Q&As on OASIS also contain guidance on surgical wounds, infusions, vision, dyspnea and completing assessments, among other topics.

Note: For the OCCB Q&As, go to www.oasis certificate.org and select “resources.” The NPUAP guidance is at www.npuap.org and the WOCN guidance is at www.wocn.org.

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