OASIS Alert

Be sure you complete the required steps before you answer 'yes'.

Scenario: On Friday you admit Mr. B, a patient with complex needs who is new to your agency. On your second visit on Saturday you compile a list of medications for M2000 (Drug regimen review). Later that day, back in the office, you review the medications and discover a significant medication issue (e.g., side effects that concern the patient). You contact the physician's office to report your concern and an hour later you receive a call back from the physician on call, who is not the patient's physician and is unfamiliar with this patient. The on-call physician decides the issue can safely wait and tells you to contact the patient's regular physician on Monday. How do you answer M2002?

M2002 (Medication follow-up) asks:Was the physician or the physician-designee contacted within one calendar day to resolve clinically significant medication issues, including reconciliation? Answer choices are 0-No and 1-Yes.

Correct answer: 0-No. The intent of this question is to find out if potentially clinically significant problems identified during the drug regimen review were addressed with the physician within one calendar day following identification of the medication issue, the Centers for Medicare & Medicaid Services says in its OASIS C instructions. But a new question and answer released Jan. 20 clarifies what the clinician must do before you are allowed to answer "yes" to M2002.

In the above scenario, you completed the first step by reviewing the medications and identifying the problem. You also completed the second step by contacting the physician and receiving a return call from the on-call physician. You may have thought you completed the further step of reconciliation, since the physician decided the issue was not urgent and could wait until Monday, but that is not what CMS means by "including reconciliation," Q&A 16 explains.

"Due to the contacted physician's unfamiliarity with the patient, you were directed to contact the primary care practitioner on Monday. Therefore no one reconciled, or formulated a plan to reconcile, the specific medication issue identified within one calendar day, so '0-No' should beselected," CMS instructs.

Further clarification: In Q&A 17, CMS clarifies another factor that plays into whether you can answer "yes" to M2002. Not only must the physician respond and reconcile the issue before the end of the calendar day following the day the problem was identified. The physician's response and the reconciliation also must occur before the end of day five after the start of care assessment. M2002 must be answered within the timeframe allowed for the start of care OASISassessment (five days), CMS says. This ensures compliance with the conditions of participation regarding the comprehensive assessment, CMS adds.

Instead: The response and reconciliation will be captured when you answer M2002 on any resumption of care OASIS assessment, CMS instructs.