Home Health & Hospice Week

Quick Quiz: Do you know when a SCIC assessment is required?

With punishing new alternative sanctions for surveys on deck for July, you need to make sure your OASIS processes don’t trigger harsh survey consequences.

Civil money penalties and payment suspensions go into effect as surveyor tools next summer. To guard against sanctions as the result of poor OA-SIS practices, make sure you have a handle on the pertinent Conditions of Participation.

484.55 COP: Comprehensive Assessment Of Patients (G330-G342)

This COP requires that a qualified clinician must collect the OASIS data, said Arlene Maxim of A.D. Maxim Consulting, Maxim Seminars, and The National Coding Center in Troy, Mich.

Each patient must have a comprehensive assessment, regardless of payment source, within the required timeframe, Maxim explained during the Eli-sponsored audioconference "Rules of Engage-ment: Getting Back to Basics — Conditions of Par-ticipation, Part II." Remember, you must develop the plan of care (POC) based upon the assessment and review it at least every 60 days.

Surveyors are training on the OASIS assessment and will go through the items in detail, Maxim cautioned.

484.55A Standard: Initial Assessment Visit (G331-G333_

This standard requires that a registered nurse completes the initial assessment and the comprehensive assessment when skilled nursing is ordered, Maxim said. For non-Medicare patients, if the patient will receive only physical therapy, speech therapy, or occupational therapy, the appropriate therapist can conduct the start of care visit.

The initial assessment must occur within 48 hours of referral, Maxim said. If the visit happens after the 48-hour window, be sure to document the patient’s request for a more convenient time in the record, and notify the physician of the patient’s request for a delayed start of care. If the physician ordered the later start of care, make sure there is an order in the chart specifying the delayed SOC date.

Tip: If a patient has sutures that require removal before a PT-only case, the RN must do the initial assessment, Maxim said.

484.55B Standard: Completion Of Comprehensive Assessment (G334-G336)

This standard requires that the comprehensive assessment be completed in a timely manner, consistent with the patient’s immediate needs, but no later than five calendar days after the start of care, Maxim said

"Except as provided in paragraph (b)(3) of this section, a registered nurse must complete the comprehensive assessment and for Medicare patients, determine eligibility for the Medicare home health benefit, including homebound status," according to the COPs.

Mind the dates: Expect surveyors to review the SOC visit date (M0030) and compare it with the first billable visit, Maxim said. If a nurse does all OASIS assessments for your agency, but the therapist doesn’t get out to see a therapy-only patient until two days after the assessment, the first billable visit is the day the therapist sees the patient.

Surveyors will also compare M0030 (SOC date) with M0090 (OASIS completion date) for inconsistencies, Maxim said. Be sure to review your referral documents with inconsistent dates and make appropriate corrections or documentation.

"The surveyor will be looking for inconsistent dates and documentation to support the reason for late SOC dates," Maxim said.

484.55c Standard: Drug Regimen Review (G337)

This standard requires the comprehensive assessment to include a review of all medications the patient is currently using. The assessment should identify any potential adverse effects and drug reactions, including ineffective drug therapy, significant side effects, significant drug interactions, duplicate drug therapy, and noncompliance with drug therapy, Maxim said.

Don’t miss: The surveyor will expect to see a thorough review of-all-patient drugs, including prescription drugs, over-the-counter drugs, vitamins, herbs, etc, Maxim said. Problems found in your compliance with this standard can result in a condition-level citation as well as an immediate jeopardy situation.

Surveyors will be looking for agency policies regarding medication reconciliation when therapists complete a SOC assessment, Maxim said.

484.55D Standard: Update Of The Comprehensive Assessment (G338)

The financial SCIC may be a thing of the past, but the clinical one lives on. This standard requires agencies to update and revise the comprehensive assessment (including OASIS) as frequently as the patient’s condition warrants due to a major decline or improvement in the patient’s health status — a significant change in condition.

The term "major decline or improvement in the patient’s health status" is the impetus for collecting and reporting OASIS data in the following situations, Maxim said:

• As defined by the HHA (reason for assessment 5, other follow-up);
• To assess a patient on return from an inpatient facility, other than a hospital, if the patient was not discharged upon transfer (resumption of care); and
• As determined by CMS.

The surveyor can determine that the pa-tient’s care plan/OASIS should have been updated for an unexpected significant improvement or de-cline, Maxim said. Staff not completing SCIC assessments could be found out of compliance for this "high-priority" standard, she cautioned. Don’t let the demise of financial SCICs trick you into forgetting that new assessments and care plans due to clinical SCICS are still required.