OASIS Alert

Begin focusing on OASIS C details right away.

Now that the final OASIS C assessment form is out, it's time to pay close attention to your agency's preparations.

The final OASIS C form 12.4 -- released as a draft on July 15 and in Office of Management and Budget-approved form July 29 -- contains only minor changes from version 12.2, experts say.

Background: The Centers for Medicare & Medicaid Services received final OMB approval for version 12.4 after months of waiting.

The planned implementation date of January 2010 still stands, CMS confirmed in the Open Door Forum for home health providers held July 29.

Problem: The crucial item-by-item guidance on how to answer the 114 OASIS questions (formerly known as Chapter 8) won't be released until mid-September, CMS reported in the forum.

The changes to the new version of the OASIS C data set -- version 12.4 -- are pretty minor, explains consultant Patricia Jump, president of Acorn's End Training & Consulting in Stewartville, Minn. No new questions have been added and none deleted. The numbering remains the same and the number of items is also the same, Jump summarizes. Two changes in the this version are:

• M1000 (From which of the following inpatient facilities was the patient discharged during the past 14 days). This item contains one less response possibility. The "hospital emergency department" option was deleted. This change makes the question somewhat more consistent with M2410 (To which inpatient facility has the patient been admitted) in which an emergency department is not considered an inpatient facility.

"Although they have left the specialty hospital options, at least all the choices in M1000 now are actually inpatient facilities," says Judy Adams, president and CEO of Adams Home Care Consulting in Chapel Hill, N.C.

• M1900 (Prior functioning ADL/ IADL). The check-boxes in the grid for this item now have numbers attached to the responses: independent = 0; needed some help = 1; and dependent = 2.

This addition of scoring numbers also shows up in the latest OASIS C for items M2040 (Prior medication management); M2100 (Types and sources of assistance); M02250 (Plan of care synopsis); and M2400 (Intervention synopsis).

Look for tweaks in pressure ulcer questions. In a move that will likely head off a number of OASIS questions from clinicians, CMS has clarified these pressure ulcer questions:

• M1306 (Does this patient have at least one unhealed pressure ulcer at stage II or higher or designated as unstageable). In the latest OASIS C, CMS deletes the descriptor "nonepithelialized" following the word "unhealed."

"This continues to be an area where we really need the Documentation Guidance/Implementation manual or updated information from Wound Ostomy Continence Nurses Society or National Pressure Ulcer Advisory Panel to understand the meaning of the terms 'non-epithelialized' and 'newly epithelialized,'" Adams says.

Another possibility: The world wide conference on pressure ulcers is scheduled for this year and a major point of discussion is the correct term to use to reflect healing status of pressure ulcers, Adams reports.

• M1307 (The oldest non-epithelialized stage II pressure ulcer that is present at discharge). By changing the question slightly, CMS clarifies that this question is specific to the discharged patient. The additional response option, "Developed since the most recent SOC/ROC assessment: record date pressure ulcer first identified," and a new N/A response option more clearly direct the clinician to what CMS wants.This will identify whether "the pressure ulcer developed under the home health watch," Adams says.

Warning: This item is likely to be part of Home Health Compare, Jump says. It may also be incorporated into adverse events, surveys, and even payment, she worries.

• M1308 (Current number of unhealed [non-epithelialized] pressure ulcers at each stage). Changes to this item make the instructions much clearer because the parenthesis following the question is shorter and more direct.

The form tells you to enter "0" if there are no unhealed pressure ulcers and instructs that the question specifically excludes stage I ulcers. The clinician also is no longer limited to reporting four pressure ulcers now, Adams points out.

Lines instead of boxes make it easier to enter numbers, and the column headings clarify where to put your answers. The clinician completes the first column at start of care, resumption of care, follow-up, and discharge and includes only current pressure ulcers. The clinician completes the second column only at follow-up and discharge. This column asks for the number of pressure ulcers in column one (current ulcers other than stage I) that were also present on admission (that is, on the most recent SOC/ROC assessment).

• M1310 (Pressure ulcer length). The instructions for this section clarify that the measurements in this item are only for stage III or IV pressure ulcers. The same is true for M1312 (Pressure ulcer width) and M1314 (Pressure ulcer depth). If the patient has no stage III or IV pressure ulcers, the directions instruct the clinician to skip to M1320.

Caution: If you use a wound flow sheet, you must be careful that the information in the two places matches, Jump warns. Work with vendors to be sure this item is linked to other wound assessment tools your clinicians may use at the same time points, she advises.

• M1320 (Status of most problematic [observable] pressure ulcer). In the first re-sponse -- "0" -- CMS deletes the term "re-epithelialized" and replaces it with "newly epithelialized."

• M1324 (Stage of most problematic unhealed [observable] pressure ulcer). CMS adds the term "unhealed" to this question, following the word "problematic."

This underscores the difference between OASIS C and OASIS B-1, Adams observes. On  OASIS B-1 clinicians are supposed to collect information on both healed and unhealed stage III and IV pressure ulcer.

The new OASIS C data set changes one question each for stasis ulcers and surgical wounds:

• M1334 (Status of most problematic [observable] stasis ulcer). CMS adds one new response selection: "0 -- newly epithelialized."

• M1342 (Status of most problematic [observable] surgical wound). In this item CMS changes response "0" from "re-epithelialized" to "newly epithelialized" as in item M1320.