Home Health Coding and OASIS Expert

Put ‘worsening’ on top of your training list.

The OASIS-C1 brought many changes to pressure ulcer items, but CMS isn’t done tweaking these often confusing questions yet. And medication items are also on the update list for the OASIS-C2.

In the newly released OASIS-C2 item set taking effect in January 2017, the Centers for Medicare & Medicaid Services modifies and renumbers “select medication and integumentary items to standardize with other post-acute settings of care (M1311, M1313, M2001, M2003, and M2005),” CMS notes on its website. Examples include:

M2003 Medication Follow-up and M2005 Medication Intervention. CMS reworded the current M2002 and M2004 to specify contacting the physician “by midnight of the next calendar day.” Currently, it merely says “within one calendar day.”

“I do not agree with the timeframe changes in M2003 and M2005, although I know this has been a problem for most agencies because MDs are not always accessible same day,” says consultant Lynda Laff, RN, BSN, COS-C, with Laff Associates in Hilton Head Island, S.C. “Many medication issues can be life threatening and need same-day attention,” Laff stresses. “But it is actually (not always but sometimes) the fault of the MD,” for example, lacking backup on call support or follow up, Laff acknowledges.

M1311 Current Number of Unhealed Pressure Ulcers at Each Stage. The new chart for pressure ulcers will look very different than the current one in M1308. Instead of six subitems identified a, b, c, d1, d2, and d3, the item labels the six subitems a-f. And each subitem will include the prompt “Number of these Stage 2 pressure ulcers that were present at most recent SOC/ROC” with a separate box to fill in. Instructions at the bottom of the chart instruct “Omit ‘A2, B2, C2, D2, E2 and F2’ on SOC/ROC.”

M1313 Worsening in Pressure Ulcer Status since SOC/ROC. For subitems a-c in the item that updates M1309, CMS instructs clinicians to “Indicate the number of current pressure ulcers that were not present or were at a lesser stage at the most recent SOC/ROC.” In subitems d-f, CMS says “for pressure ulcers that are Unstageable due to slough/eschar, report the number that are new or were at a Stage 1 or 2 at the most recent SOC/ROC.” HHAs are going to have to hit the definition of “worsening” hard in their staff training in 2017, advised Cindy Krafft, PT, MS, of Kornetti & Krafft Health Care Solutions in her podcast, “OASIS-C2 — Overview of Key Changes.” Clinicians must understand what the term really means, she urged. Make it a part of your educational plan going forward.

Note: For a free PDF copy of OASIS-C2, email editor Jan Milliman at janm@codinginstitute.com with “OASIS-C2” in the subject line.