Medicare Compliance & Reimbursement

Question: Our software vendor claims that an upcoming upgrade will allow our agency to reduce the amount of OASIS training we provide clinicians because the software has the ability to pre-populate items based on assessment data. I am worried that the updated software will lead to compliance issues. What do you think?

Answer: You’re right to be concerned. In order to be compliant with the Condition of Participation, 484.55, The Comprehensive Assessment of Patients, requires the assessing clinician completing the comprehensive assessment to read the question exactly as written in the data set, carefully consider each available response option, and then choose the appropriate OASIS response. “An agency’s software may not ‘answer’ or ‘generate’ the OASIS response for the assessing clinician,” the Centers for Medicare & Medicaid Services (CMS) points out in the fourth quarter, 2013 OASIS Q&As.

CMS does allow for some exceptions to how items can be displayed in a limited number of items. For example, the formatting for especially long or complex items such as the diagnosis items (M1020/M1022/M1024) and pressure ulcer item M1308 can be modified to fit a computer screen. But the hard copy print out must match the data set. And any modifications must not have an impact on the accuracy of the item score. 

Note: For more OASIS information, subscribe to Eli’s OASIS Alert at www.aapc.com/codes/coding-newsletters/my-oasis-alert.