OASIS Alert

Neglect this Condition of Participation and risk survey sanctions.

If you’re not doing a new assessment when your patient has a significant change in his condition, you could be risking survey citations. Make sure you know when — and when not to — complete a SCIC assessment.

Myth: When home health agencies were first required to complete OASIS assessments, some nurses thought they needed to complete a SCIC every time a patient had a medication change, said Arlene Maxim, RN founder of A.D. Maxim Consulting, A.D. Maxim Seminars, and The National Coding Center, in Troy, Mich. That’s not the case, but neither is the opposite extreme of never completing a SCIC, she said during the Eli-sponsored audioconference “Rules of Engagement: Getting Back to Basics — Conditions of Participation, Part II.”

Since the Centers for Medicare & Medicaid Services has eliminated the financial ramifications of SCICs, agencies may have let their “other follow-up” processes go by the wayside. You should complete an RFA 5  — Other Follow-Up assessment when your patient has a major change (improvement or deterioration) you didn’t expect, Maxim said. “If a patient changes to a point where the plan of care needs to change, you should do a SCIC.”

For example: Your nurse has been seeing a patient for two to three weeks when suddenly he starts having joint pain and needs to have physical therapy added to his POC. This is a situation when you should complete a SCIC assessment, Maxim said.

Another example: Your patient’s pressure ulcer has advanced from a Stage 2 to a Stage 3. It’s time to complete a SCIC, Maxim said.

Having a documented policy that describes when your agency will complete SCIC assessments is a helpful audit safeguard. “Every surveyor will have their own vision of what a SCIC should be, but the thing that will protect agencies most is to have a policy that defines what they consider a SCIC,” Maxim said. This way the agency isn’t caught up in the surveyor’s definition.

The Centers for Medicare & Medicaid Services’ rules are vague on this issue, Maxim said. So, make sure your policy is in compliance with the rules, but not in excess of the rules, she said.

Bottom line: If the patient improves or deteriorates in a way that your agency didn’t envision at the start of care, you need to do a SCIC assessment.