OASIS Alert

Item Focus:

M0090: Report The Correct Date Or Risk OASIS Errors

Make use of the 5-day window with this item.

You need only enter a date in M0090 — Date assessment completed, but entering the right date is essential. M0090 is used to calculate whether your agency completes the OASIS within the required time frame. Miss the mark, and you’ll have an error reported on the OASIS validation report provided with the transmission of each OASIS batch.

Establish the Basics

OASIS item M0090 — Date assessment completed — asks you to specify the actual date the assessment was completed.

Enter the date in month/day/year format (07/05/2013).

Timepoints: You’ll complete M1240 at all time points.

Know when the Assessment is Complete

Many clinicians consider an assessment complete once they have gathered and documented all of the OASIS items, says Pat Jump, with Rice Lake, Wis.-based Acorn’s End Training & Consulting.

But the Centers for Medicare & Medicaid Services (CMS) isn’t asking about paperwork completion in M0090. Instead, CMS wants to know when you were finished collecting all of the data related to the client’s assessment.

In other words, the date you list in M0090 is the last date you collected information from the patient, caregiver or physician for the current assessment, says Judy Adams, RN, BSN, HCS-D, HCS-O, with Adams Home Care Consulting in Asheville, N.C.

Timing: Under the OASIS conditions of participation, HHAs have five days from the start of care (SOC) date (M0030) to collect information, Adams says. Given how much information you must collect at the SOC especially, it’s important to remember that you do have that five-day window to gather it all, she says. And you’ll often need to use a good portion — or even all — of the five days to gather everything that will impact the calculation of the Home Health Resource Group.

For example, Adams points out that it frequently takes longer than one day to:

1. Obtain the verbal orders for the process of care interventions to complete M2250; or

2. Review medications because a family member has them stored away from the patient’s home; or

3. See stasis ulcers that are covered by a dressing on the day of the assessment when there are orders to change the dressing within that five-day window; or

4. Contact family members for additional history about the patient.

Waiting for a response from the physician regarding the client’s health status can also hold you up, Jump says.

For example: Suppose you have collected all the data required for the assessment on Monday. That same day, you make a phone call to the physician to clarify a diagnosis. The physician doesn’t return the phone call to provide the clarification until Wednesday. In this situation, the M0090 date would be Wednesday, Jump says.

Consequences: Missing an opportunity to collect information during the allowed window for any of the above can result in unnecessary negative outcomes, Adams says.

Don’t Be Blindsided by SOC

Sorting out time frames as they relate to the Start of Care (SOC) visit and M0090 may also be confusing for clinicians, says Jump. “By Medicare’s definition, the SOC is always the first billable visit,” she reminds. And a visit made only to complete a comprehensive assessment of the client isn’t a Medicare-billable visit. “To be a billable visit, the clinician must perform a skilled service, based on Medicare’s definition of ‘skilled.’”

For example: Suppose your agency’s policy is to have an RN complete the SOC OASIS assessment in a therapy-only case. The therapist would establish the SOC for this episode and that SOC date would be the first billable visit made by the therapist, Jump says. “In such a situation, the RN may not begin the SOC OASIS assessment until the date of the therapist’s visit.”

Carrying the example further, if the therapist is making his or her visit on Wednesday, the RN may not begin the SOC OASIS assessment any earlier than Wednesday, Jump says. The RN is allowed to make the visit at an earlier time than the therapist, as long as it is on the same day, she says.

For example: The RN could complete the SOC OASIS assessment in the morning on Wednesday and the therapist could complete the skilled therapy visit in the afternoon of that same Wednesday.