Home Health Coding and OASIS Expert

Clarification to come as new requirement draws nearer.

Caution: Low BMI is a risk factor for developing pressure ulcers. That’s why the Centers for Medicare & Medicaid Services plans to ask you to help track height and weight data as part of the new Percent of Residents or Patients with Pressure Ulcers that are New or Worsened quality measure. Here’s what’s in the works for this new measure.

In a draft of the OASIS changes necessary for measure NQF #0678, height and weight are included in a new M item: “Height and Weight — While measuring, if the number is X.1 – X.4 round down; X.5 or greater round up.”

Part A of the draft item states “Height (in inches). Record most recent height measure since the most recent SOC/ROC.” Part B says “Weight (in pounds). Base weight on most recent measure in last 3 days; measure weight consistently, according to standard agency practice (e.g., in a.m. after voiding, before meal, with shoes off, etc.).”

How To Measure?

Obtaining weight presents a much bigger challenge in home care than other settings, commenters told the agency in comments on the proposed rule. This measure “is a great tool for CMS to use on MDS assessments for SNFs and LTCs, but it is not appropriate for Home Care providers unless the requirement for an accurate height and weight is removed,” said Marlene Seerup from Minnesota in her comment letter response to the proposed rule. “As a home care provider, I know that it is often difficult, if not impossible, to obtain an accurate height and especially weight on a patient who is confined to their home and at the greatest risk of developing pressure ulcers. If they are in a wheelchair and/or bedbound, the only way to obtain a weight is if the patient has a scale on their bed which is very unusual,” she said.

“In a facility, they have access to [wheelchair] scales and scales on hoyer lifts. Home Care patients do not have these options,” Seerup continued. “The majority of the time, if the patient has a transfer lift device, it is a hand-cranked device with no scale.” Patients often aren’t able to leave their homes for physician appointments, “so they do not have the option of being weighed there either,” she added. “This is just not a feasible expectation for Home Care patients.”

If a patient’s medical condition “does not support a need for ongoing assessment of weight, the absence of a scale would not be addressed as part of the plan of care,” pointed out a letter from St. Joseph’s Home Care in New York. Clinicians can ask patients their height or consult the medical record, St. Joseph’s notes. “‘Reported’ heights would likely be documented for many patients but the reliability of the reports is questionable, especially as patients’ age increases and they suffer from both spinal compression and memory deficits.”

Wrinkle: “I am not clear what is meant by ‘base weight’” in Part B of the draft item, the rep from St. Joseph’s said. “I would want to be very clear with staff about the expectation for recording a weight which is measured during the visit versus a weight which could be reported by the patient based on an ‘in home’ measurement or based [on] a recent MD appointment or hospitalization.”

Response: “We recognize that there will be instances in which obtaining height and weight cannot occur, and coding response options will be available in order to indicate when such data cannot be obtained,” CMS assured providers in the final rule. “We intend to issue specific guidance through the OASIS manual on obtaining these data, including a definition of ‘base weight.’ We will also offer support through training, Open Door Forums, and other communication mechanisms.”

Note: See the draft OASIS changes at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/OASIS-January_2017_July2015.pdf. For more tips and strategies on running a successful home health agency, see Eli’s Home Care Week. Information on subscribing is online at www.codinginstitute.com/newsletters/eli-home-care-week.html.