OASIS Alert

2 scenarios to help clear up your questions.

True or False: When a home health agency's policy is that the nurse always does the start of care OASIS assessment, the nurse's visit should always be the first visit.

Answer: False. The timing of the nurse's assessment visit depends on who else will be caring for the patient during that episode.

Scenario #1: If the orders are for both nursing and therapy for this patient, the nurse must make the first visit to do at least the initial Medicare assessment. The initial assessment determines the patient's immediate needs and eligibility for the Medicare home health benefit, according to Medicare regulations. "In accordance with the regulations, the initial visit must be made by a registered nurse or, for therapy-only cases, a qualified therapist," the State Operations Manual says in section 2202.1.

This initial assessment does not need to include the comprehensive OASIS assessment, although it often does, confirms Pat Sevast with the Centers for Medicare & Medicaid Services. Medicare rules allow the clinician up to five days to complete the assessment.

Scenario #2: In a therapy-only episode, the nurse may not do the OASIS assessment before the date of the therapist's first skilled visit, CMS instructs in Chapter 8 of the OASIS Implementation Manual. The nurse can do the OASIS on the date of the therapist's visit or after that date, but within the five-day window from the first skilled visit.

"In a therapy-only case, only the therapist's performance of a skilled service can begin the episode," CMS instructs. If the nurse does the SOC assessment before that date, the data entry software will consider it missing for that episode, CMS says.

Note: The revised version of Chapter 8 is at http://www.cms.hhs.gov/center/hha.asp, select "OASIS User's Manual," then select "OASIS Manual Updates." Or email editor Marian Cannell at marianc@eliresearch.com with "Chapter 8" in the subject line. The State Operations Manual is at http://www.cms.hhs.gov/manuals/downloads/som107c02.pdf.