Home Health Coding and OASIS Expert

Does your training process need an overhaul?

Are you ready for the OASIS-C1? Despite the ICD-10 delay, the deadline for transitioning to the new version of the OASIS is just around the corner. Make certain you know how the updated form will impact your agency.

Background: The Centers for Medicare & Medicaid Services original plan was to debut the OASIS-C1 along with the commencement of ICD-10 on Oct. 1, 2014, says Pat Jump with Rice Lake, Wis.-based Acorn’s End Training & Consulting. However, because ICD-10 has been delayed until Oct. 1, 2015, CMS plans to move forward with an interim version of the modified data set, referred to as the “OASIS-C1/ICD-9.”

Deadline: The OASIS-C1/ICD-9 changes will take effect on Jan. 1, 2015 and will remain in effect until ICD-10 is implemented or until otherwise determined by CMS, Jump says.

The OASIS-C1/ICD-9 will contain all the planned OASIS-C1 data set modifications except for those that are impacted by the ICD-10 delay.

These five OASIS-C1 data items that require the use of ICD-10 codes will be replaced with their original OASIS-C items in OASIS-C1/ICD-9, Jump says:

• M1010 (Inpatient Diagnosis) will replace M1011
• M1016 (Diagnosis Requiring Treatment Change) will replace M1017, and
• M1020/M1022/M1024 (Primary, Other, and Payment Diagnoses) will replace their ICD-10 parallels M1021/M1023/M1025.

In addition, watch for the deletion of M1012, the current inpatient surgical procedure item, effective Jan. 1, 2015. CMS announced in April 2011, that the inpatient surgical procedure data is no longer required. Agencies can currently answer “NA” or “UK” to M1012, but must still answer the data item until it is deleted, says Lisa Selman-Holman, JD, BSN, RN, HCS-D, COS-C, HCS-O, consultant and principal of Selman-Holman & Associates and CoDR — Coding Done Right in Denton, Texas.

Establish Your OASIS-C1 Action Plan

The first step to success with OASIS-C1 is to understand what’s changed, says Selman-Holman. Significant changes to the vaccination items will lend clarity that is sorely lacking in OASIS-C. Revision of the Risk for Hospitalization item means that item responses are more objective and removes professional judgment in making determinations. The OASIS-C Q&As have been cleaned up and revised as necessary for OASIS-C1 so there are many changes in store for everyone from clinical directors to QA to coders to field staff. Highlights of the OASIS-C1 changes include the following, Selman-Holman says:

Minor changes include substituting “for example” for e.g., “specifically” for i.e. and always capitalizing Unstageable (and removing quotation marks). In the OASIS-C1, CMS refers to non-adherence rather than non-compliance in an effort to indicate more patient autonomy. “Most changes will be simple because Medicare is clarifying what they have already indicated as intention in previous Q&As,” Selman-Holman says. “However, sometimes new items will take more training,” 

One new item: M1309 — Worsening in Pressure Ulcer Status since SOC/ROC. Watch for more details on the changed pressure ulcer OASIS items in the next issue of Home Health Diagnosis Coding and OASIS Expert.

Three items with modified response options:

• M1308: Second column and the word non-epithelialized  removed.
• M1334 — Status of Most Problematic Stasis Ulcer: ‘0’ for newly epithelialized removed. This item was an error and needed to be corrected since stasis ulcers , once epithelialized, are no longer there.
• M1910 — Has this patient had a multi-factor Falls Risk Assessment using a standardized, validated assessment tool? Answer descriptions changed to make intent more clear.

“The changes in OASIS-C1 are all very positive for clinicians and will likely produce better outcomes because clinicians will understand them better and answer the OASIS questions more accurately,” says Lynda Laff, RN, BSN, COS-C, with Laff Associates in Hilton Head Island, S.C.

Watch Your Dates

You’ll complete an OASIS-C1 for M0090 dates of Jan. 1, 2015 and later. And you’ll complete an OASIS-C for M0090 dates in 2014. Keep in mind that you have five days after start of care to complete the SOC OASIS, so you may find yourself switching between forms as the transition deadline draws near.

For example: Suppose the SOC is on Dec. 29, 2014 but all the prescriptions are not in the home and the physician needs to be called for best practice orders. The physician returns your call on Jan. 2, 2015. You’ll answer M2250 ‘yes’ for those particular best practice interventions, but that changes the correct M0090 date to Jan. 2, 2015 meaning that you’ll need to complete the OASIS-C1 rather than the OASIS-C, Selman-Holman says. 

Tip: Where you transmit your OASIS will also change effective Jan. 1, Selman-Holman points out. You’ll need to obtain new passwords and have a plan in place for transmitting your OASIS on time through the transition.

Note: Watch for more details on all of the OASIS-C1 changes in the next issue of Home Health Diagnosis Coding and OASIS Expert.