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CATEGORY 4 A - OASIS DATA SET FORMS

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2. A105 No Debridement is a treatment to a wound and the traumatic wound does not become a surgical wound Q amp A added 06 05 Q106 M0482 M0488 Is a peritoneal dialysis catheter considered a surgical wound If it is how can the healing status of this site be determined A106 Both M0440 and M0482 should be answered Yes for a patient with a catheter in place that is used for peritoneal dialysis You should consider the catheter for peritoneal dialysis or an AV shunt a surgical wound as are central lines and implanted vascular access devices To answer M0488 the healing status of a wound can only be determined by a skilled assessment in person It is possible for such a wound to be considered fully granulating the best level the wound could attain on this particular item for long periods of time but it is also possible for such wounds to be considered early partial granulation or not healing if the site becomes infected These sites would not be considered as non healing unless the signs of not healing are apparent Such a site because it is being held open by the line itself may not reach a fully granulating state Assessing the healing status of such a wound is slightly more difficult than a typical surgical site As long as a device is present the wound will be classified as a Surgical wound Follow the Wound Ostomy and Continence Nurses guidelines OASIS Guidance Document found at http Awww wocn org to d
3. A185 Response option 3 assistance or services provided by other community resources is an appropriate response in this situation Q186 M0880 What if my patient is being discharged from a payer source in order to begin care under a new payer source A186 The OASIS items do not request a reason for discharge only whether the patient is continuing to receive services if he she remains in the community In this situation the appropriate response for M0870 would be 1 Patient remained in the community and the correct response for M0880 would be 3 Yes assistance or services provided by other community resources Q187 M0890 What if M0830 was already answered yes How should I answer this item A187 You should respond to M0890 appropriately for the situation M0830 might have been answered yes for a separate instance of emergent care not necessarily relating to this hospitalization If the patient was hospitalized after having been seen in the emergency room then M0830 would be answered yes and M0890 would most likely be answered with response 1 Hospitalization for emergent unscheduled care Q188 M0903 Do the dates in M0903 and M0090 always need to be the same What situations might cause them to differ A188 When a patient is discharged from the agency with goals met the date of the assessment M0090 and the date of the last home visit M0903 are likely to be the same Under three situations however
4. because he she requires the assist of another for washing difficult to reach areas A137 The correct response for the patient described here would be Response 2 able to bathe in the shower or tub with the assistance of another person c for washing difficult to reach areas because that response describes that patient s ability at that time The general instructions on the page preceding the ADL IADL items in Chapter 8 of the OASIS User s Manual state that the patient s ability on the day of the assessment should be recorded and that if the patient s ability varies on that day the clinician should choose the response that describes the patient s ability more than 50 of the time not the patient s ability to perform more than 50 of the tasks Q amp A added 06 05 Q138 M0670 Please clarify how the patient s ability to access the tub shower applies to M0670 A138 M0670 defines the bathing item to identify the patient s ability to wash the entire body Guidance for this item also indicates that when medical restrictions prevent the patient from accessing the tub shower his her bathing ability will be scored at a lower level Tasks related to transferring in and out of the tub or shower are evaluated and scored when responding to M0690 Transferring and they are not considered part of the bathing tasks for M0670 Q amp A added 06 05 Q139 M0670 A patient is unable to participate in the bathing tasks and is totally
5. occurs at least daily and affects the patient s sleep appetite physical or emotional energy concentration personal relationships or ability or desire to perform activity While the pain does not need to be constant to be considered intractable the combination of the pain its effects on the patient s quality of life and activities and the effort to manage the pain must be involved or ever present Q amp A added 06 05 Q78 M0440 For M0440 Integumentary Status please clarify CMS s interpretation of a skin lesion A78 Lesion is a broad term used to describe an area of pathologically altered tissue Wounds sores ulcers rashes crusts etc are all considered lesions So are bruises or scars In responding to the item the only lesions that should be disregarded are those that end in ostomy e g tracheostomy gastrostomy etc or peripheral IV sites central line sites are considered to be surgical wounds For additional types of skin lesions please consult a physical assessment text Q79 M0440 How many different types of skin lesions are there anyway A79 Many different types of skin lesions exist These may be classified as primary lesions arising from previously normal skin such as vesicles pustules wheals or as secondary lesions resulting from changes in primary lesions such as crusts ulcers or scars Other classifications describe lesions as changes in color or texture e g maceratio
6. the most appropriate description of the situation Q62 M0390 Are reading glasses bought at the grocery store considered corrective lenses What about a patient who uses a magnifying glass to read the paper is this a corrective lens A62 Reading glasses are considered corrective lenses A magnifying glass is not considered an example of corrective lenses Q63 M0390 How is vision evaluated for the patient who is too disoriented and cognitively impaired for the clinician to assess A63 A caregiver may be able to assist by demonstrating the patient s response to an object that is familiar to him her Alternatively this could be a situation where the patient is not able to respond thus is nonresponsive response 2 Q64 M0390 Does information on vision documented in OASIS have to be backed up with documentation elsewhere in the patient s record A64 A patient who has partially or severely impaired vision responses 1 or 2 is likely to require adaptations to the care plan as a result of these limitations Therefore it is likely that the vision impairments would be included in additional assessment data or as rationale for care plan interventions Q65 M0400 Our agency would like clarification concerning M0400 Hearing and Ability to Understand Spoken language in patient s own language If a patient speaks Spanish and there is an interpreter it is difficult to ascertain the level of complexity of interpreted instructions How
7. 14 days prior to the assessment what would be the best response for M0510 A116 In either of these situations the appropriate response would be no Q117 M0520 Is the patient incontinent if she only has stress incontinence when coughing A117 Yes the patient is incontinent if incontinence occurs under any situation s Q118 M0520 A new urologist has just started referring patients who have a urostomy or ureterostomy What should mark for M0520 A118 A urostomy or ureterostomy is considered an ostomy for urinary drainage The appropriate response therefore is 0 no incontinence or catheter The appropriate skip pattern should then be followed Q119 M0520 A patient is determined to be incontinent of urine at SOC After implementing clinical interventions e g Kegel exercises biofeedback and medication therapy the episodes of incontinence stop At the time of discharge the patient has not experienced incontinence since the establishment of the incontinence program At discharge can the patient be considered continent of urine for scoring of M0520 to reflect improvement in status A119 Assuming that there has been ongoing assessment of the patient s response to the incontinence program implied in the question this patient would be assessed as continent of urine Therefore Response 0 no incontinence or catheter is an appropriate response to M0520 Timed voiding was not specifically mentioned as an inte
8. Participation Home Health Agencies in the Participation category Q11 Our agency completes the Reduced Burden Recertification assessment that has only 26 items Is this sufficient to meet the CoP for the follow up assessment A11 The twenty six OASIS items are not a complete comprehensive assessment and must also have either the agency determined components of the Follow Up assessment or a Clinical note describing the health status of the patient Please refer to Appendix C of the OASIS User s Manual available at http www cms hhs gov oasis usermanu asp for sample clinical forms demonstrating the integration of OASIS items into comprehensive assessments one for each time point Q12 In some places in the OASIS User s Manual the prior 14 days is referred to as being a point in time and in other places it is referred to as a period of time Are the 14 days prior assessment items to be based on what the patient was doing on the 14th day prior to the assessment or on what the patient could usually do the majority of the time during the 14 day period prior to the assessment A12 In the ADL IADL data items M0640 through M0800 the patient s ability 14 days prior to the start or resumption of care is addressed In these items prior indicates the patient s status on the 14th day before the start or resumption of care Adhere strictly to this 14 day time point If the patient was in a hospital at that time describe
9. ability to speak and orally verbally express himself herself not general communication ability If the patient depends entirely on sign language or writing and is unable to speak response 5 applies The clinician would want to document the patient s general communication ability in another location in the clinical record as this is important for care provision Q68 M0410 Can this item be answered if a patient is trained in esophageal speaking or uses an electrolarynx A68 Augmented speech through the use of esophageal speech or an electrolarynx is considered oral verbal expression of language Q69 M0420 How can you assess pain in a nonverbal patient A nonresponsive patient A69 Nonverbal or nonresponsive patients experience pain and careful observation establishes its presence and an estimation of its severity The clinician should observe facial expression frowning gritting teeth note changes in pulse rate respiratory rate perspiration pallor pupil size or irritability A nonverbal but responsive patient could also utilize a visual analog scale to describe the pain being experienced Q70 M0420 For pain to interfere does it have to prevent that activity from occurring Or just alter or affect the frequency or method with which the patient carries out the activity A70 For pain to interfere with activity it does not have to totally prevent the activity Examples of how pain can interfere with activity with
10. agency may intend that the private pay source will pay the entire cost of the patient s home care that usually cannot be verified at start of care and may not be determined until the care is completed Q25 M0150 Please clarify what Title V and Title XX programs are A25 Title V is a State determined program that provides maternal child health and crippled children s services which can include home health care Title XX of the Social Security Act is a social service block grant available to States that provide homemaking chore services home management or home health aide services Title Ill also mentioned in Response 6 to M0150 is part of the Older Americans Act of 1965 that gives grants to State Agencies on Aging to provide certain services including homemaker home delivered meals congregate nutrition and personal care aide services at the State s discretion Q26 M0150 Is M0150 Current Payment Sources for Home Care limited to payment for home care services If a patient had out of pocket expenses for DME or for prescription or over the counter medications should Response 10 Self pay be marked A26 If equipment or medications essential or integral to the home care episode are being paid by the patient in part or full then Response 10 Self Pay should be marked Q amp A added 06 05 Q27 M0150 A patient with traditional Medicare is referred for skilled services and upon evaluation is determined to not b
11. be lifted from the bed to a chair He cannot turn himself in bed and is unable to bear weight or pivot How would I respond to M0690 A149 Response 3 is the option that most closely resembles the patient s circumstance you describe The patient is unable to transfer and is unable to bear weight or pivot when transferred by another person Because he is transferred to a chair he would not be considered bedfast confined to the bed even though he cannot help with the transfer Responses 4 and 5 do not apply for the patient who is not bedfast Q150 M0690 If other types of transfers are being assessed e g car transfers floor transfers should they be considered when responding to M0690 A150 Because standardized data are required only the specific transfer tasks listed in M0690 should be considered when responding to the item Based on the patient s unique needs home environment etc transfer assessment beyond bed to chair toilet commode or tub shower transfers may be indicated Note in the patient s record the specific circumstances and patient s ability to accomplish other types of transfers Q151 M0690 If a patient takes extra time and pushes up with both arms is this considered using an assistive device A151 You appear to be asking about a patient who is not bedfast Remember that M0690 evaluates the patient s ability to safely perform three types of transfers bed to chair on and off toilet or commode and in
12. etc Q97 M0445 M0464 We have been advised that a pressure ulcer is always a pressure ulcer and should be staged as it was at its worst Does this apply to stage 1 and stage 2 pressure ulcers A97 Based on current advances in wound care research and the opinion of the National Pressure Ulcer Advisory Panel NPUAP CMS has modified its policy for coding the healing status of Stage 1 and Stage 2 pressure ulcers This policy became effective September 1 2004 Stage 1 pressure ulcers heal to normal appearing skin and are not at increased risk for future ulcer development Stage 2 ulcers generally heal to nearly normal appearing skin but may result in scar tissue formation Healed stage 2 pressure ulcers only minimally increase the future risk of pressure ulcers at that location The complete guidance on this topic is provided at www cms hhs gov oasis training During the SOC or subsequent comprehensive assessments of the patient if it is found that a patient has a healed Stage 1 or 2 pressure ulcer the responses for OASIS data items are as follows M0440 Does this patient have a Skin Lesion or Open Wound e If the patient has a healed Stage 1 pressure ulcer and no other pressure ulcers OR skin lesions wounds the response would be No e If the patient has a healed Stage 2 pressure ulcer and no other pressure ulcers OR skin lesions wounds the response may be either No or Yes depending on the clinician s physic
13. having a current surgical wound If needed the manual can be downloaded from http Avww cms hhs gov oasis usermanu asp Q110 M0482 M0488 I ve never seen a nonobservable surgical wound in my agency Why is this item even included A110 There are situations where surgeons do not want others to remove the dressings that they have placed In such situations agencies know there is a surgical wound present but they are unable to describe the wound status because they cannot observe the wound Without M0486 the responses to the surgical wound item responses might be difficult to evaluate In the national repository data nearly 10 i e 9 8 of patients with surgical wounds at SOC ROC had nonobservable wounds Q111 M0482 M0488 Following the WOCN guidance is it correct to say that a surgical wound healing by primary intention would be healed when the healing ridge is no longer palpable Only fine pink collagen tissue the beginning of a scar is visible A111 Yes CMS collaborated with the WOCN Association to publish guidelines named the OASIS Guidance Document in August 2001 The WOCN document was developed by consensus among the WOCN panel of experts This guidance documents that a surgical wound closed by primary intention would be fully granulating if the incision is well approximated with complete epithelialization of the incision if there is no avascular tissue if there is no sign of infection and if the healing ridge is well defin
14. hospital rehabilitation facility nursing home or inpatient hospice for 24 hours or more Note that the text of the item indicates that it means transfer to an inpatient facility Q21 M0100 For a one visit Medicare PPS patient is Reason for Assessment RFA 1 the appropriate response for M0100 Is it data entered Is it transmitted Is a discharge OASIS completed A21 You are correct that RFA 1 is the appropriate response on M0100 for a one visit Medicare PPS patient The OASIS data should be encoded data entered to generate a Health Insurance Prospective Payment System HIPPS code and transmitted to the State system No discharge assessment is required as the patient received only one visit Agency clinical documentation should note that no further visits occurred No subsequent discharge information must be collected or submitted but the patient s name will appear on the data management system DMS agency roster report for six months after which time the name will be dropped If the patient were admitted again to the agency and a subsequent SOC assessment submitted the agency would receive a warning that the new assessment was out of sequence This would not prevent the agency from transmitting that assessment however Q22 M0100 Which reason for assessment RFA should be used when a patient is transferred to another agency A22 When a patient is transferred from one agency to another the patient must be discharged using RFA 9
15. items would be the patient s street address telephone number or directions to the patient s residence Q3 PTS Must the clinician write down mark every single piece of information recorded on the Patient Tracking Sheet e g could clerical staff enter the address ZIP code etc A3 Consistent with professional and legal documentation principles the clinician who signs the assessment documentation is verifying the accuracy of the information recorded At the time of referral it is possible for clerical staff to record preliminary responses to several OASIS items such as the address or ZIP code The assessing clinician then is responsible to verify the accuracy of these data Q4 What do the M000 numbers stand for A4 The M signifies a Medicare assessment item The following four characters are numbers that identify the specific OASIS item Q5 M0016 What do I enter in M0016 Branch ID after January 1 2004 if I am an HHA with no branches a parent a subunit or a branch A5 If you are a HHA with no branches please enter N followed by 9 spaces If you are a parent HHA that has branches please enter P followed by 9 spaces If you area subunit with no branches please enter P followed by 9 spaces If you are a branch enter the Branch ID number assigned by the Regional Office RO The Branch identifier consists of 10 digits the State code as the first two digits followed by Q upper case foll
16. last time an assessment was completed Emergent unscheduled within 24 hours care is the definition that we are using and following CMS has not changed the definition of M0830 It remains the same as the current manual The clinician needs to use the information for any necessary care planning changes for example was there a change or addition in medications or treatments The item does not justify why the patient sought emergent care only that emergent care occurred or not The 24 hour timeframe is a guideline to see if the need for the physician visit was emergent or not If a patient is listed on an adverse event report then the agency needs to investigate the event to determine whether or not the care for this patient was problematic Q amp A added 06 05 Q178 M0830 Please clarify how to respond for the patient who dies in the ER before being formally admitted to the inpatient facility and for the patient who is pronounced dead on arrival at the ER A178 The patient who dies in the emergency room is NOT considered to have died while under the care of the agency and therefore is NOT considered a death at home This patient would have a transfer assessment completed which would require that M0830 be completed This is true even though the patient was never formally admitted to the inpatient facility because the facility was actively providing care at the time of the patient s death In contrast the patient who is pronou
17. on Reporting OASIS information requires that the OASIS data be retained as part of the clinical documentation To access the CoP go to http Awww cms hhs gov providers hha oasis click on Conditions of Participation Home Health Agencies in the Participation category Q10 If the OASIS data elements are being filled out for the Start of Care Follow up and Discharge is there an additional nursing note required as a Federal regulation Or is an additional nursing note as a summary of data gathered not required assuming the OASIS elements include all necessary patient information A10 As noted in CFR 484 55 the condition of participation CoP regarding comprehensive assessment each patient must receive a patient specific comprehensive assessment that accurately reflects the patient s current health status and includes information that may be used to demonstrate the patient s progress toward achievement of desired outcomes The preamble to this rule also notes that the OASIS data set is not intended to constitute a complete comprehensive assessment Each agency must determine according to their policies and patient population needs the additional assessment items to be included in its comprehensive assessment forms Clinical notes are to be completed as required by 42 CFR 484 48 and the home care agency s clinical policies and procedures To access the CoP go to http www cms hhs gov providers hha oasis click on Conditions of
18. presence of the feeding tube and diet information should be detailed elsewhere in the clinical documentation Q157 M0710 What if the patient cannot carry his food to the table He is able to feed himself to chew and to swallow A157 You should respond to this item based on the assistance needed by the patient to feed himself once the food is placed in front of him If no assistance is needed then response 0 applies If some assistance is required response 1 applies Because you indicate that the patient is able to feed himself response 2 would not be appropriate Q158 M0720 Should a therapeutic diet prescription be considered when assessing the patient s ability to plan and prepare light meals for M0720 For example if a patient is able to heat a frozen dinner in the microwave or make a sandwich but is NOT able to plan and prepare a simple meal within the currently prescribed diet until teaching has been accomplished for THAT diet or until physical or cognitive deficits have been resolved would the patient be considered able or unable to plan and prepare light meals A158 M0720 identifies the patient s cognitive and physical ability to plan and prepare light meals or reheat delivered meals While the nutritional appropriateness of the patient s food selections is not the focus of this item any prescribed diet requirements and related planning preparation should be considered when scoring M0720 Therefore a patient who is
19. presence or absence of a caregiver If the patient is able to safely get to and from the toilet with assistance then response 1 should be selected as this reflects their ability regardless of the availability of a consistent caregiver in the home Q amp A added 06 05 Q147 M0680 Is the transfer on off the toilet included in responding to M0680 What about the transfer on off the bedside commode What about the transfer on off the bed pan A147 M0680 does not include the transfer on and off the toilet for response levels 0 and 1 or on off the bedside commode for response 2 as both these transfers are specifically addressed in responding to M0690 Transferring The transfer on and off the bedpan is considered for M0680 response level 3 If the patient requires assistance to get on off the bedpan then he she would not be considered independent in using the bedpan and response 4 would be the best response Q amp A added 06 05 Q148 M0680 If a patient uses a bedside commode over the toilet would this be considered getting to the toilet for the purposes of responding to M0680 A148 Yes a patient who is able to safely get to and from the toilet should be scored at response levels 0 or 1 even if they require the use of a commode over the toilet Note that the location of such a commode is not at the bedside and the commode is functioning much like a raised toilet seat Q amp A added 06 05 Q149 M0690 My patient must
20. recover and a secondary diagnosis of cancer for which gradual deterioration was expected would the prognosis be good because it refers only to the hip fracture A54 The focus of M0260 is the overall prognosis for recovery from this episode of illness for which the home care is being provided In the example if the patient s recovery from the hip fracture is complicated by metastasis of the cancer to the bone then the patient s condition might be noted as response 0 Poor according to the clinician s assessment Patient prognosis is also required for the Plan of Treatment Q55 M0280 Life Expectancy is assessed at the Start of Care Resumption of Care and at Discharge We don t have the opportunity to change this response if there is a change in the patient and there is no intervening inpatient stay What should we do A55 The reduced burden OASIS did remove the opportunity to update this item with another assessment RFA4 5 Please document any changes in your patient in the patient s clinical record when there is a change in his her status Q56 M0340 How should we respond to M0340 for patients living in an Assisted Living Facility ALF A56 Rules for licensing Assisted Living Facilities vary from State to State and the actual physical structural arrangements vary from one facility to another so the answer must be selected that is most appropriate for the individual situation This item simply asks who the patient lives wit
21. service If the service was not provided by any of those entities but as a contracted service then M0830 should be scored based on who ordered the x ray Q amp A added 06 05 Q176 M0830 If the patient receives a home visit from a nurse practitioner from the doctor s office in response to a fall or increased pain or other problematic symptoms would this be considered emergent care A176 Yes the non home care nurse s home visit would be considered emergent care and would be reported based on the entity hospital doctor s office outpatient clinic that sent the nurse Q amp A added 06 05 Q177 M0830 Should all unscheduled MD visits be considered emergent care for purposes of responding to M0830 Or only those which the clinician judges to represent an MD visit being utilized in lieu of an emergency room visit For instance if the clinician calls the physician with patient reports of marked calf pain tenderness and acute SOB and the physician wants the patient to come into his office would that be considered emergent care If the clinician calls the physician to report that the patient s knee range of motion is not progressing as rapidly as expected and the doctor tells the patient to move up their appointment by a few days and come in today would that be considered emergent care A177 In M0830 Emergent Care we are trying to determine if the patient received emergent medical care for an illness or injury since the
22. the Correct Diagnosis Coding Practices document originally posted by CMS in 2001 has been updated and is posted at http www cms hhs gov providers hhapps home It is titled OASIS Diagnosis Reporting Case Examples Q45 M0250 Does M0250 refer to the therapies the patient is receiving when the staff member walks in to do the OASIS assessment What if the patient is known to need enteral feedings and is scheduled for setup post OASIS assessment Please clarify A45 M0250 refers to therapies the patient is receiving at the time of the assessment visit or which the patient is ordered to receive as a result of the assessment visit For example if the assessment reveals the existence of dehydration and the clinician s communication results in an order for IV therapy response 1 would be marked Q46 M0250 Does a central line OR subcutaneous infusion OR epidural infusion OR intrathecal infusion OR an insulin pump OR home dialysis including peritoneal dialysis count in responding to M0250 A46 Only one question must be answered to determine whether these examples count as IV or infusion therapy is the patient receiving such therapy at home If the patient were receiving such therapy at home then response 1 for M0250 would be appropriate If the infusion therapy is administered in the physician s office or outpatient center or dialysis center response 4 would be marked Q amp A edited 06 05 Q47 M0250 Does an IM
23. the field only allows for two sets of codes When we include this item in our clinical forms can we add more lines A34 M0190 requests the two primary diagnoses that were actively treated during the inpatient facility stay not all diagnoses that the patient may have Agencies should carefully consider whether additional information is needed and if so how only the most relevant information is listed in a and b of M0190 OASIS items must be reproduced in the agency clinical forms exactly as they are written If the agency desires additional information the most appropriate course of action may be to insert an additional clinical record item immediately following M0190 Q35 M0190 It takes days sometimes even a week to get the discharge form from the hospital How can we complete this item in a timely manner A35 Information regarding the condition s treated during the inpatient facility stay has great relevance for the SOC ROC assessment and for the plan of care The agency may instruct intake personnel to gather the information at the time of referral Alternatively the assessing clinician may contact the hospital discharge planner or the referring physician to obtain the information Q36 M0190 Can anyone other than the assessing clinician enter the ICD codes A36 Coding may be done in accordance with agency policies and procedures as long as the assessing clinician determines the primary and secondary diagnoses and rec
24. the status that day Several other OASIS items e g M0170 M0200 etc address events that may have occurred within the last 14 days In responding to those items the entire 14 day period should be considered For example was the patient discharged from an inpatient facility during that time Q13 There seems to be a discrepancy between the instructions in the OASIS User s Manual regarding M0890 M0895 and M0900 In Appendix B these three items are omitted from the discharge assessment yet the items are included in the Inpatient Transfer with Discharge grouping Should these items be included in the discharge assessment A13 The answer to this question depends on whether your agency uses separate assessment forms for Transfer to an Inpatient Facility and for Discharge not to an inpatient facility If it has separate forms these three data items should be included in the assessment for Transfer to Inpatient Facility and not included in the Discharge assessment On the Transfer to an Inpatient Facility these items are included in the list of assessment items to be completed Under Discharge from Agency Not to an Inpatient Facility these items are correctly not included If your agency uses only one form that includes both Transfer and Discharge however these items should be included Q14 Our agency has created separate clinical documentation forms for Transfer to Inpatient Facility and for Discharge On our Discharge form we om
25. the subsequent items of M0810 Patient Management of Equipment and M0820 Caregiver Management of Equipment which address IV infusion therapy and enteral parenteral equipment or supplies Q52 M0250 If the discharge visit includes discontinuing IV or infusion therapy should the OASIS item M0250 reflect the presence of these services on the discharge assessment A52 Yes if the IV is being discontinued the day of the assessment visit then those respective services can be marked as present at the assessment Q amp A added 06 05 Q53 M0250 A patient has an order on admission for an IV infusion to be given prn if specific parameters are present None of the parameters exist at SOC and no IV line is inserted What is the appropriate response to M0250 A53 If the patient receives an IV infusion as a result of the SOC assessment i e the predetermined parameters are met then response 1 is appropriate If the parameters are not met at the SOC assessment then response 1 does NOT apply Also note that since there are physician orders for IV therapy based on potential changes in the patient s condition no Significant Change in Condition SCIC would result if the parameters were met later in the episode Q amp A added 06 05 Q54 M0260 Does Overall Prognosis M0260 refer to the prognosis of the primary diagnosis or the overall prognosis For instance if a patient had a primary diagnosis of fractured hip from which he would
26. they be scored based on their ambulatory status because they do not fit the definition of chairfast A154 Item M0700 addresses the patient s ability to ambulate so that is where the clinician s focus must be Endurance is not included in this item The clinician must determine the level of assistance is needed for the patient to ambulate and choose response 0 1 or 2 whichever is the most appropriate Q amp A added 06 05 Q155 M0700 How would I score a patient who does not use an assistive device but does sometimes need help on level even surfaces A155 A patient who needs intermittent assistance including any combination of hands on assistance supervision and or verbal cueing to ambulate safely would be scored as a 1 on M0700 A patient who needs continuous assistance including any combination of hands on assistance supervision and or verbal cueing to ambulate safely would be scored as a 2 able to walk only with the supervision or assistance of another person at all times Q amp A added 06 05 Q156 M0710 How should M0710 be answered if the patient is being weaned from a feeding tube The tube is still present but is not being used for nutrition A156 If the tube is being used to provide all or some nutrition responses 3 5 apply Once the tube is no longer used for nutrition even if it remains in place the patient s ability to feed himself herself should be reported using response 0 1 or 2 The
27. to complete the assessment Social workers are not able to initiate a qualifying Medicare home health benefit but may support other qualifying services In the Medicare Conditions of Participation CoP CFR 484 34 conducting a comprehensive assessment of the patient is not considered a service that a social worker could provide To access the CoP go to http www cms hhs gov providers hha oasis click on Conditions of Participation Home Health Agencies in the Participation category Q14 M0090 We have 5 calendar days to complete the admission start of care assessment What date do we list on OASIS for M0090 Date Assessment Completed when information is gathered on day 1 3 and 5 A14 Generally you would enter the last day that assessment information was obtained on the patient in his her home if all clinical data items were completed However if the clinician needs to follow up off site with the patient s family or physician in order to complete a clinical data item M0090 should reflect that date Q15 M0090 We had a patient admitted to the hospital on April 15 and found out about it on April 19 When we enter the transfer patient discharged assessment M0100 reason for assessment 7 into HAVEN we get a warning message that the record was not completed within correct timing guidelines M0090 date should be no earlier than M0906 date AND no more than 2 days after M0906 date A15 That message is intended to be a remin
28. 0 be marked as 0 A165 Following the instructions quoted above the clinician must determine the total number of daily doses involved to determine what is true most of the time For example a patient who had two medications one of which was taken once daily and one of which was taken 4 6 times a day e g Parkinson s medications and was independent with taking both medications the first time in the morning but needed reminders to take the remaining 3 5 doses of the second medication Response 1 would be appropriate Q amp A added 06 05 Q166 M0780 When scoring M0780 Management of Oral Medications should medication management tasks related to filling and reordering obtaining the medications be considered A166 No Tasks related to filling reordering and obtaining medications are considered part of the instrumental activity of daily living shopping task and they are evaluated during the scoring of M0760 Q amp A added 06 05 Q167 M0780 When scoring M0780 Management of Oral Medications should assessment include only prescription medications Or should over the counter oral medications be included as well A167 Scoring of M0780 should include all oral medications prescribed and non prescribed that the patient is currently taking and are included on the plan of care Q amp A added 06 05 Q168 M0800 Sometimes the physician orders indicate that the nurse must administer the injectable medication How does this aff
29. 19 M0090 A provider has decided to complete discharge assessments for all patients when payers change because they believe that by doing so their reports will better indicate their patients outcomes Before making this policy shift they need answers to the following questions Can the agency perform the RFA 09 and RFA 01 on the same visit If so what is the discharge date for the RFA 09 at M0090 If so what is the admission date for RFA 01 at M0090 Will recording of the same date for both of these assessment result in errors when transmitted to the state agency 2979 A19 Under normal business practices one home health visit should not include two types of assessments and be billed to two payer sources The discharge date for the RFA 09 Discharge from Agency should be the last date of service for the payer being terminated The admission date for the new Start of Care RFA 01 assessment should be the next scheduled visit according to the plan of care The agency may send a batch including both assessments to the state system An edit is in place at the state system to sort for an assessment to close an open patient episode prior to opening a new episode Q amp A added 06 05 Q20 M0100 Does transfer mean transfer to another non acute setting or transfer to an inpatient facility A20 Transfer means transfer to an inpatient facility i e the patient is leaving the home care setting and being transferred to a
30. A83 M0440 should be answered yes since a lesion is present Additional documentation that describes the burn should be included in the clinical record but burns are not addressed in the OASIS items The appropriate ICD 9 CM code for the burn should be entered in M0230 Primary Diagnosis for accurate documentation Q84 M0440 Do all scars qualify as skin lesions A84 Yes ascar meets the definition of an area of pathologically altered tissue Q amp A added 06 05 Q85 M0440 If the patient had a port a cath but the agency was not providing any services related to the cath and not accessing it would this be coded as a skin lesion at M0440 A85 For M0440 you would answer YES for a lesion and continue answering the questions until you come to M0482 Does this patient have a surgical wound Respond Yes 1 The port a cath or mediport site is considered a surgical wound even if healed over The presence of a wound or lesion should be documented regardless of whether the home care agency is providing services related to the wound or lesion Q86 M0440 Are implanted infusion devices or venous access devices considered surgical wounds at M0440 A86 Yes the surgical sites where such devices were implanted would be considered lesions at M0440 and would be included in the total number of surgical wounds M0484 It does not matter whether the device is accessed at a particular frequency or not Q87 M0440 How do we document other woun
31. CATEGORY 4 OASIS DATA SET FORMS and ITEMS Category 4A General OASIS forms questions Q1 Will there be any further revisions to the OASIS B1 data set currently posted on the OASIS website A1 The most current version of the OASIS data set will always be available on the OASIS website http www cms hhs gov oasis oasisdat asp When revisions are necessary in the future we will post them on the website well in advance of their effective dates Q2 When integrating the OASIS data items into an HHA s assessment system can the OASIS data items be inserted in an order that best suits the agency s needs i e can they be added in any order or must they remain in the order presented on the OASIS form A2 Integrating the OASIS items into the HHA s own assessment system in the order presented on the OASIS data set would facilitate data entry of the items into the data collection and reporting software However it is not mandatory that agencies do this Agencies may integrate the items in such a way that best suits their assessment system Some agencies may wish to electronically collect their OASIS data and upload it for transmission to the State As long as the agency can format the required CMS data submission file for transmission to the State agency it doesn t matter in what order the data are collected Q3 Are agencies allowed to modify skip patterns through alternative sequencing of OASIS data items A3 While we encourage HHAs to i
32. IS items is based on the patient s status on the day of the assessment Does the day of the assessment refer to the calendar day or the most recent 24 hour period A17 Since home care visits can occur at any time of the day and to standardize the time frame for assessment data the day of the assessment refers to the 24 hour period directly preceding the assessment visit This standard definition ensures that fluctuations in patient status that may occur at particular times during the day can be considered in determining the patient s ability and status regardless of the time of day of the visit Q amp A added 06 05 Category 4B OASIS Data Items Q1 PTS Can the Patient Tracking Sheet be combined with another form such as the agency s referral form A1 The agency may choose to use the Patient Tracking Sheet as any other clinical documentation integrating additional items as desired If the agency typically collects other items at SOC and updates them only as necessary during the episode of care these items might be good choices to integrate with the other Tracking Sheet items The patient s telephone number might be an example of such an item Q2 PTS Can other agency specific items be added to the Patient Tracking Sheet A2 The agency can incorporate other items into the Patient Tracking Sheet PTS as needed for efficient care provision Examples of such items that would fit nicely with the OASIS PTS
33. able to complete the mobility and cognitive tasks that would be required to heat a frozen dinner in the microwave or make a sandwich but who is currently physically or cognitively unable plan and prepare a simple meal that complies with a medically prescribed diet should be scored as a 1 unable to prepare light meals on a regular basis due to physical cognitive or mental limitations until adequate teaching learning has occurred for the special diet or until related physical or cognitive barriers are addressed This is a critical assessment strategy when considering the important relationship between this IADL and nutritional status A poorly nourished patient with limited ability to prepare meals is at greater risk for further physical decline Q amp A added 06 05 Q159 M0730 My patient s son drives her to doctor s appointments because she has not driven for years The patient prefers her son do this rather than taking public transportation How would I respond to M0730 A159 Remember that the item addresses what the patient is able to do not what she prefers A person who has not driven for years is not likely to be able to safely and independently drive a car at the time of the assessment However if the patient were able to use a regular or handicap accessible public bus response level 0 would be appropriate Q160 M0760 If select response 0 or response 1 will the patient s homebound status be questioned A160 For all t
34. al assessment of the healed wound site gt If the patient has no scar tissue formation from the healed Stage 2 pressure ulcer the accurate response is No gt If the patient has some residual scar tissue formation the response is Yes M0445 Does this patient have a Pressure Ulcer e If the patient has a healed Stage 1 or 2 pressure ulcer and no other pressure ulcers the accurate response is No following the skip pattern as indicated Q amp A added 06 05 Q98 N0445 N0464 Can a previously observable Stage 4 pressure ulcer that is now covered with slough or eschar be categorized as Stage 4 A98 No a pressure ulcer that is covered with eschar cannot be staged until the wound bed is visible The status of the pressure ulcer needs to correspond to the visual assessment by the skilled clinician on the date of the assessment This is documented on the Wound Ostomy and Continence Nurses WOCN Association website at www wocn org inthe WOCN Guidance Document and at the NPUAP site at www npuap org Q amp A added 06 05 Q99 M0445 M0464 If a wound heals and breaks down again should it be staged at its prior level or should it be staged on the current level of breakdown A99 The type of wound is not identified here but this response pertains to a healed pressure ulcer This is the only type of wound that clinicians can stage The appropriate response to this question for pressure ulcers will depend on the stage of t
35. are we to answer this A65 You will need to ask the interpreter to help you determine at what level the patient is responding Responses to No observable impairment 0 and Unable to hear and understand familiar words or common expressions consistently or patient nonresponsive 4 should be relatively simple to determine To determine the difference between levels 1 2 or 3 you can interact with the interpreter to determine with what difficulty the patient is responding Inasmuch as the assessment includes assistance from an interpreter your clinical documentation of the visit should indicate the presence of an interpreter who assists with communication between clinician and patient Q66 M0400 Is it correct that both auditory and receptive language functions are included in responding to this item Therefore a deaf patient who processes spoken language effectively using lip reading strategies is scored at response level 4 Unable to hear and understand because the item measures the combination of BOTH hearing and comprehension A66 Yes M0400 does include assessment of both hearing AND understanding spoken language A patient unable to hear even with the use of hearing aids if the patient usually uses them would be scored at response level 4 Q amp A added 06 05 Q67 M0410 How dol respond to this item if the patient uses sign language What about a patient who communicates by writing A67 This item addresses the patient s
36. ary or chart if the list is created for the patient by another person The statement for response 1c someone develops a drug diary or chart pertains to someone other than the patient developing the aid What you need to assess is whether the patient must use this list to take the medications at the correct times If he she does require the list then response 1 is the appropriate choice Q164 M0780 Some assisted living facilities require that facility staff administer medications to residents If the patient appears able to take oral medications independently how would the clinician answer M0780 A164 M0780 refers to the patient s ability to take the correct oral medication s and proper dosage s at the correct times Your assessment of the patient s vision strength and manual dexterity in the hands and fingers as well as cognitive ability will allow you to evaluate this ability despite the facility s requirement You would certainly want to document the requirement in the clinical record Q165 M0780 For a patient who is independent response level 0 with all medications except one which he she is unable to take without being administered by someone else would the last statement in the item by item instructions If patient s ability to manage medications varies from medication to medication consider the total number of medications and total daily doses in determining what is true most of the time require that M078
37. ata collection was completed Does a new SOC need to be completed at the time of the change in payer source A28 There is a discussion of payer source change in Chapter 8 Section E of the OASIS User s Manual Different States different payers and different agencies have varying responses to these payer change situations so we usually find it most effective to ask Does the new payer require anew SOC HHAs usually are able to work their way through what they need to do if they answer that question If the new payer source requires a new SOC Medicare is one that DOES require a new SOC then it is recommended that the patient be discharged from the previous pay source and re assessed under the new pay source i e anew SOC comprehensive assessment The agency does not have to re admit the patient in the sense that it would normally admit a new patient and all the paperwork that entails a new admission If the payer source DOES NOT require a new SOC then the schedule for updating the comprehensive assessment continues based on the original SOC date The HHA simply indicates that the pay source has changed at M0150 OASIS data collection and submission would continue for a Medicare Medicaid patient changed to another pay source without a discharge Because the episode began with Medicare or Medicaid as a payer the episode continues to be for a Medicare Medicaid patient Transmittal 61 posted January 16 2004 includes a section on special bil
38. avigate the stairs to the tub shower A134 a The patient s environment can impact his her ability to complete specific ADL tasks If the patient s tub or shower is nonfunctioning or not safe then the patient is currently unable to use the facilities Response 4 or 5 would apply depending on the patient s ability to participate in bathing activities outside the tub shower b The patient s medical restrictions mean that the patient is unable to bathe in the tub or shower at this time Select response 4 unable to bathe in shower or tub and is bathed in bed or bedside chair or 5 unable to effectively participate in bathing and is totally bathed by another person whichever most closely describes the patient s ability at the time of the assessment c If the patient s fear is a realistic barrier to her ability to get in out of the shower safely then she is unable to bathe in the tub shower If she refuses to enter the shower even with another person present either response 4 or 5 would apply depending on the patient s ability at the time of assessment If she is able to bathe in the shower when another person is present then response 3 would describe her ability d The patient s environment must be considered when responding to the OASIS items If the patient chooses not to navigate the stairs but is able to do so with supervision then her ability to bathe in the tub or shower is dependent on that supervision to allow her t
39. bathed by a caregiver but the caregiver bathes the patient in the shower i e lifts the patient into a shower chair rolls patient to the shower and bathes the otherwise passive patient Response 5 states that the patient is unable to effectively participate in bathing and is totally bathed by another person Please clarify if this patient would be noted to be at response level 5 because they are unable to effectively participate in bathing and are totally bathed by another person or at level 3 because the patient requires the presence and assistance of another person to bathe in the shower A139 If the patient truly is unable to effectively participate in any part of the bathing tasks in the shower response 5 is appropriate If the patient is able to participate at all in the bathing tasks in the shower then response 3 is appropriate Q amp A added 06 05 Q140 M0670 If the only reason the patient can t bathe in the tub is because they can t perform the transfer safely even with equipment and assistance should they be at response level 4 or 5 Unable to use the shower or tub even though the only reason is the transfer status and transferring is not supposed to be considered in responding to M0670 A140 The tub transfer should not be considered when responding to M0670 However the response for M0670 should differentiate patients who are able to bathe in the tub or shower i e responses 0 1 2 or 3 from those who are unable t
40. cilities NF Q32 M0175 M0175 refers to the inpatient facility from which the patient was discharged within the last 14 days Please define 14 days A32 During the past 14 days refers to the two week period immediately preceding the start of care resumption of care SOC ROC date or the first day of the new certification period at follow up The easiest way to determine this is to refer to a calendar For example if the SOC ROC is Wednesday August 20 look at a calendar to refer to the same day of the week two weeks ago which in this case is August 6 For follow up assessments count fourteen days before the first day of the new certification period For more information please refer to Medicare Resources for Researching Inpatient Discharges within 14 Days of a Home Health Admission found at http Awww cms hhs gov medlearn matters mmarticles 2004 SE0410 pdf Q amp A edited 06 05 Q33 M0180 In OASIS field M0180 if there is no date do you just fill in zeros A33 As noted in the skip instructions for item M0175 if the patient was not discharged from an inpatient facility within the past 14 days i e M0175 has a response of NA M0180 and M0190 should be skipped If the patient was discharged from an inpatient facility during the past 14 days but the date is unknown you should mark UK at M0180 and leave the date blank Q34 M0190 How would additional inpatient facility diagnoses and ICD 9 CM codes be entered into M0190 since
41. cy would like clarification of the question concerning how M0430 Intractable pain is assessed In our agency intractable pain is often interpreted as cancer pain However the term used in the question not easily relieved opens the door to very wide interpretation A74 In this data item we are assessing the presence of intractable pain as defined in Chapter 8 of the OASIS User s Manual Intractable pain refers not only to cancer pain but also to pain that is ever present which may affect the patient s sleep appetite physical or emotional energy concentration personal relationships or ability or desire to perform activity This type of pain likely interferes with the patient s activities and needs to be considered when developing the plan of care Q75 M0430 A patient takes narcotic pain medications continuously and is currently pain free Medication side effects including constipation nausea and drowsiness affect the patient s interest and ability to eat walk and socialize Based on the information provided would this patient be considered to have intractable pain A75 Intractable pain refers to pain that is not easily relieved occurs at least daily and affects the patient s sleep appetite physical or emotional energy concentration personal relationships or ability or desire to perform activity Intractable pain is ever present The clinician making the assessment will determine if the patient s pain meets the compon
42. der that you should complete a transfer assessment within 48 hours of learning of it The regulation states that the assessment must be completed within 48 hours of learning of a transfer to an inpatient facility so in this case the assessment has been completed in compliance The warning does not prevent the assessment from being locked and transmitted If you find that this warning occurs consistently you may want to examine whether your staff are appropriately tracking the status of patients under their care Q16 M0090 Is the date that an assessment is completed in M0090 required to coincide with the date of a home visit When must the date in M0090 coincide with the date of a home visit A16 The start of care SOC resumption of care ROC follow up and discharge assessments reason for assessments RFA 1 3 4 5 and 9 for M0100 must be completed through an in person contact with the patient therefore these assessments will coincide with a home visit The transfer or death at home assessments RFAs 6 7 or 8 for M0100 will have the date the agency learns of the event recorded at M0090 However in the rare instance that the clinician needs to follow up off site with the patient s family or physician in order to complete a specific clinical data item that the patient was unable to answer M0090 should reflect that date Q17 M0090 If an HHA s policy requires personnel knowledgeable of ICD 9 CM coding to complete the diagnos
43. ds that are not surgical pressure ulcers or stasis ulcers at M0440 A87 Remember that OASIS items are only PART of a comprehensive assessment and include only those items that have proven useful for outcome measurement and risk factor adjustment During the early stages of the research on which OASIS items are based the status of many such lesions were tested for their utility as outcome measures Only the types of wounds that worked for outcome measurement or risk factor adjustment have been carried forward in OASIS though other types of wounds are extremely important to document in the clinical record The presence of ANY wound or lesion other than ostomies should be noted by a yes response to M0440 Q88 M0440 M0482 Does a cataract surgery or a gynecological surgical procedure by a vaginal approach result in a skin lesion for M0440 and a surgical wound for M0482 A88 No Cataract surgery and gynecological surgical procedures by a vaginal approach are not included in M0440 or M0482 M0440 captures skin lesions or an open wound to the integumentary system Only certain types of wounds are described by OASIS We would expect that any discharge swelling pain etc from either procedure would be reported in the agency s clinical documentation Q amp A added 06 05 Q89 M0440 M0445 M0468 Are diabetic foot ulcers classified as pressure ulcers stasis ulcers or simply as wound lesions at M0440 and M0445 A89 The clinician will hav
44. e response options including a hospital emergency room You should mark M0830 with response 1 Hospital emergency room In this situation since the patient was admitted to the hospital following the emergency room visit you would also complete the items for Transfer to the inpatient facility RFA 6 or 7 to M0100 Q173 M0830 The patient was held in the ER suite for observation for 36 hours Was this a hospital admission or emergent care A173 If the patient were never admitted to the inpatient facility this encounter would be considered emergent care The time period that a patient can be held without admission can vary from location to location so the clinician will want to verify that the patient was never actually admitted to the hospital Q174 M0830 The patient had a planned visit for cataract surgery at the outpatient surgical center Is this emergent care A174 Emergent care is defined as an unscheduled visit to any emergent medical services The situation you described was a planned visit and thus is not considered emergent care Q175 M0830 If a patient receives portable x ray in their home place of residence after a fall is this considered emergent care for responding to M0830 And if so what response is selected A175 Yes this would be considered emergent care and should be reported as such on M0830 The response selected should be based on the physician s office hospital or clinic that provided the
45. e homebound and therefore not eligible for the home health benefit The patient agrees to pay privately for the skilled services Should M0150 include reporting of response 1 Medicare traditional fee for service A27 The purpose of M0150 is to identify any and all payers to which any services provided during this home care episode are being billed Although the patient described is a Medicare beneficiary response 1 of M0150 Medicare traditional fee for service would not be marked since the current situation described does not meet the home health benefit coverage criteria In fact since Section 704 of the Medicare Prescription Drug Improvement and Modernization Act of 2003 temporarily suspended OASIS data collection for non Medicare and non Medicaid patients if the services will not be billed to Medicare or Medicaid then no OASIS collection would be required for this patient although if desired the agency may voluntarily collect it as part of the still required comprehensive assessment If at some point during the care a change in patient condition results in the patient becoming homebound and otherwise meeting the home health benefit coverage criteria then a new SOC assessment would be required on which response 1 Medicare traditional fee for service would be indicated as a payer for the care Q amp A added 06 05 Q28 The patient s payer source changes from Medicare to Medicaid or private pay The initial SOC OASIS d
46. e is not the primary pay source for a given episode should the patient s Medicare number be entered Q10 The patient s Medicare number should be entered whether or not Medicare is the pay source for the episode Keep in mind that Medicare is often a secondary payer even when another payer will be billed first In order to bill Medicare as a Secondary Payer the patient must be identified as a Medicare patient from the start of care Q11 M0072 With regard to M0072 what is the Primary Referring Physician ID A11 For item M0072 we are requesting the current UPIN number for now however we have allowed for the new national provider number NPI that will be assigned in the future When the NPI number is finalized and published we will provide additional guidance Q12 M0072 For M0072 are you requesting the ID of the physician who sent the referral or the ID of the primary physician responsible for the patient and who will sign the Plan of Care They may be different A12 If these are different you should use the same physician information used for filing Medicare or other claims to complete M0072 This should be the ID of the physician who signs the plan of care Q13 M0080 Why are Social Workers not included on OASIS item M0080 A13 In item M0080 Discipline of Person Completing Assessment you will find the initials of clinicians RN PT SLP ST OT who can initiate a qualifying Medicare home health service and are able
47. e start of home care which would be while the patient was in the hospital Q129 M0640 Must see the patient comb his her hair or brush his her teeth in order to respond to this item A129 No as assessment of the patient s coordination manual dexterity upper extremity range of motion hand to head hand to mouth etc and cognitive emotional status will allow the clinician to evaluate the patient s ability to perform grooming activities Q130 M0640 Is toileting hygiene part of this item A130 The term toileting hygiene typically is used to refer to the activities of managing clothing before and after elimination and of wiping oneself after elimination If these are the activities implied by this question the response is no toileting hygiene is not part of this item If the question refers to the patient s ability to wash his her hands this activity is considered part of grooming Q131 M0650 If the patient is wearing a housecoat should I evaluate her ability to dress in the housecoat or in another style of clothing A131 The appropriate response should indicate the patient s ability to dress herself or the level of assistance needed to dress in whatever clothing she would routinely wear If the patient routinely wears another style of clothing the assessment should include the skills necessary to manage zippers buttons hooks etc associated with this clothing style Q132 M0650 What if the pati
48. e the agency of the type of bed and services the patient utilized Q amp A added 06 05 Q24 M0150 For M0150 Current Payment Sources for Home Care what should be the response if the clinician knows that a patient has health insurance but that the insurance typically won t pay until attempts have been made to collect from the liability insurance e g for injuries due to an auto accident or a fall in a public place A24 The purpose of this data item is to identify the current payer s for the home care episode Note that the text of M0150 asks for the current payment sources emphasis added and contains the instruction Mark all that Apply For Medicare patients the clinician should indicate at admission that the patient has Medicare coverage and any other coverage available and mark all of the appropriate responses The item is NOT restricted to the primary payer source When a Medicare patient has a private insurance pay source Medicare is always a likely secondary payer For example when a Medicare patient is involved in a car accident and someone s car insurance is paying for his her home care Medicare is the secondary payer and the response to M0150 should include either response 1 or 2 as appropriate for that patient The only way an agency can bill Medicare as a secondary payer is to consider that patient a Medicare patient from day 1 so that all Medicare required documentation data entry and data submission exist Although the
49. e to speak with the physician who must make the determination as to whether a specific lesion is a diabetic ulcer a pressure ulcer stasis ulcer or other lesion There are some very unique coding issues to consider for ulcers in diabetic patients vs ulcers in non diabetic patients and the physician should be aware of these in his her contact with the patient In responding to the OASIS items an ulcer diagnosed by the physician as a diabetic ulcer would be considered a lesion respond yes to M0440 but it would not be considered a pressure ulcer or a stasis ulcer Q90 M0450 When staging pressure ulcers are we to keep the stage the same throughout all assessment time points even though the ulcer is healing According to AHCPR guidelines for pressure ulcers we should keep the staging the same once a stage 4 it stays a stage 4 but we document if healing is occurring Are we to show that a Stage 4 went to a Stage 3 if this occurred at two different time points A90 Reverse staging of granulating pressure ulcers is NOT an appropriate clinical practice according to the National Pressure Ulcer Advisory Panel NPUAP Ifa pressure ulcer is stage 4 at Start of Care and is granulating at the follow up visit the pressure ulcer remains a stage 4 ulcer Your clinical documentation will reflect the healing process The NPUAP web site http www npuap org has valuable information and teaching tools regarding pressure ulcers documenting healing t
50. ect the response to M0800 A168 Response 2 should not automatically be selected for an injectable medication that the physician has ordered the nurse to administer M0800 requires an assessment of the patient s ability to prepare and take all prescribed injectable medications You must consider the patient s ability to draw up the correct dose using accurate aseptic technique to inject in an appropriate site using correct technique and to dispose of the syringe properly You must also consider why the physician has ordered a nurse to administer the medication Is it because of the specific medication the site or technique necessary for injection or the patient s cognitive status etc If the patient were physically and cognitively able to administer the injectable medication to follow appropriate technique and to observe the appropriate procedures for handling the medication the response 0 would be an appropriate response Be sure to make additional notes in the clinical record to document your assessment findings Q169 M0810 am unsure how to respond to M0810 or M0820 if my patient has an epidural infusion of pain medication A subcutaneous infusion A169 In M0250 it was established that patients receiving epidural infusions or subcutaneous infusions were receiving V infusion therapy Therefore M0810 and M0820 should be answered For M0810 the patient s ability to set up monitor and change equipment reliably and safely incl
51. ed Once the healing ridge has resolved a positive change the site would no longer be considered a surgical wound and should be considered a scar lesion For surgical wounds closed by secondary intention if the wound is completely covered with epithelial tissue has no avascular tissue or sign of infection the site would no longer be considered a surgical wound and should be considered a scar lesion Q amp A added 06 05 Q112 M0482 Does a cataract surgery or a gynecological surgical procedure by a vaginal approach result in a skin lesion for M0440 and a surgical wound for M0482 A112 No Cataract surgery and gynecological surgical procedures by a vaginal approach are not included in M0440 or M0482 M0440 captures skin lesions or an open wound to the integumentary system Only certain types of wounds are described by OASIS We would expect that any discharge swelling pain etc from either procedure would be reported in the agency s clinical documentation Q amp A added 06 05 Q113 M0490 How should best evaluate dyspnea for a chairfast wheelchair bound patient For a bedbound patient A113 M0490 asks when the patient is noticeably short of breath In the response options examples of shortness of breath with varying levels of exertion are presented The chairfast patient can be assessed for level of dyspnea while performing ADLs or at rest If the patient does not have shortness of breath with moderate exertion then eit
52. eferral for home health services does not qualify as a medical or treatment regimen change Q41 M0200 If the treatment regimen change occurred on the same day as the visit does this qualify as within the past 14 days A41 A treatment regimen change occurring on the same day as the assessment visit does qualify as occurring within the past 14 days Q42 Does the patient s referral and admission to the home health agency count as a medical or treatment change within the past 14 days A42 No Q43 M0210 For the medical diagnosis in the changed medication section at OASIS item M0210 does this need to be the current diagnosis we are seeing the patient for or a diagnosis that is specific for the medication A43 Item M0210 identifies the diagnosis es causing a change to the patient s treatment regimen health care services or medication within the past 14 days The ICD code can be a new diagnosis or an exacerbation of an existing condition that is specific to the changed medical or treatment regimen Also note that this item is not restricted to medications but refers to any change in medical or treatment regimen Q44 M0230 M0240 M0245 It is difficult to understand when an ICD 9 CM code must be entered at M0245 Where can we find help A44 For Clarification of OASIS items M0230 M0240 and M0245 please refer to the OASIS User s Manual Attachment D to Chapter 8 at http Awww cms hhs gov oasis usermanu asp Additionally
53. en response 0 would be appropriate Q144 M0680 If a patient is unable to get to the toilet or bedside commode and uses a bedpan for elimination what response applies if the patient is able to safely and independently complete all tasks except removing and emptying the bedpan urinal A144 In M0680 the patient does not need to empty the bedpan or urinal to be considered independent If the patient required assistance to use the bedpan urinal i e get on or off the bedpan or position the urinal Response 4 would be the best response If the patient could position the urinal or get on off the bedpan independently Response 3 would be appropriate Q amp A added 06 05 Q145 M0680 The Item by Item pages in Chapter 8 state that personal hygiene and management of clothing are not included in scoring so could independent use of bedpan as indicated by response 3 allow someone to help with clothing management and hygiene and still be considered independent A145 Tasks related to personal hygiene and management of clothing should not be considered when responding to M0680 Q amp A added 06 05 Q146 M0680 If a patient is able to safely get to and from the toilet with assistance of another person but they live alone and have no caregiver so they are using a bedside commode what should be the response to M0680 A146 The OASIS item response should reflect the patient s ability to safely perform a task regardless of the
54. ent must dress in stages due to shortness of breath What response must be marked A132 If the patient is able to dress herself himself independently then this is the response that should be marked even if the activities are done in steps If the dressing activity occurs in stages because verbal cueing or reminders are necessary for the patient to be able to complete the task then response 2 is appropriate Note that the shortness of breath would be addressed in M0490 Q133 M0670 For patients whose regular habit is to sponge bathe themselves at the lavatory what should be marked for M0670 A133 As noted in the Item by Item Tips found in Chapter 8 of the OASIS User s Manual the patient who regularly bathes at the sink or lavatory must be assessed in relation to his her ability to bathe in the tub or shower What assistance would be needed for the patient to be able to bathe in the tub or shower For example if it is determined that the patient would be able to shower or bathe in the tub if stand by assistance of another person was always available response 2 would be marked Q134 M0670 Given the following situations what would be the appropriate responses to M0670 a The patient s tub or shower is nonfunctioning or is not safe for use b The patient is on physician ordered bed rest c The patient fell getting out of the shower on two previous occasions and is now afraid and unwilling to try again d The patient chooses not to n
55. ents of the definition of intractable pain If the pain is well controlled by round the clock pharmacologic interventions then the pain may not occur daily and therefore would not be considered intractable The assessing clinician with input from the patient will determine if the pain is easily relieved and will identify the effects of the pain on the patient s activities and life Note that M0420 and M0430 are separate items and should be assessed and considered separately There is not an if response on M0420 then response on M0430 algorithm that is appropriate to follow in responding to these items Q amp A added 06 05 Q76 M0430 For intractable pain must the pain meet all three criteria listed in the item i e 1 be not easily relieved 2 occur at least daily and 3 affect the patient s sleep appetite physical or emotional energy concentration personal relationships emotions or ability or desire to perform physical activity in order to be considered intractable A76 Yes the pain must be not easily relieved be present at least daily and affect the patient s quality of life as outlined in the item wording Q amp A added 06 05 Q77 M0430 The Chapter 8 assessment strategies describe intractable pain as ever present Does this mean that if pain occurs daily but not constantly that it could not be considered intractable A77 Intractable pain refers to pain that is not easily relieved
56. etermine when healing has occurred Q107 M0482 M0488 When does a wound no longer qualify as a surgical wound When does CMS officially consider a wound to be healed A107 A wound no longer qualifies as a surgical wound when it is completely healed thus becoming a scar Utilizing skilled observation and assessment of the wound follow the Wound Ostomy and Continence Nurses guidelines OASIS Guidance Document found at htip www wocn org to determine when healing has occurred CMS does not follow time intervals in determining when a wound has healed since the healing status of the wound can only be determined by a skilled assessment and the time for healing varies widely between patients Q108 M0482 M0488 How should these items be marked when the patient s surgical wound is completely healed A108 If the patient s surgical wound has healed completely it is no longer considered a current surgical wound The resulting scar would be noted as a yes response to M0440 but M0482 would be marked no Q109 M0482 M0488 Is a mediport nonobservable because it is under the skin A109 Please refer to the definition of nonobservable used in the OASIS surgical wound items in the OASIS User s Manual nonobservable is an appropriate response ONLY when a nonremovable dressing is present This is not the case with a mediport As long as the mediport is present whether it is being accessed or not the patient is considered as
57. ff is using the OASIS correctly A4 We are not aware of any standardized quality assurance tool that exists to verify that clinical staff members are using OASIS correctly A variety of audit approaches might be used by an agency to validate the appropriate responses to OASIS items For example case conferences can routinely incorporate OASIS items as part of the discussion Multi discipline cases with visits by two disciplines on adjacent days can contribute to discussion of specific items Note that only one assessment is reported as the OASIS assessment Supervisory or peer evaluation visits can include OASIS data collection by two clinicians followed by comparison of responses and discussion of any differences Other approaches to data quality monitoring are included in the OAS S User s Manual Chapter 12 available at http Awww cms hhs gov oasis usermanu asp Q5 How do I cut and paste the OASIS questions on the website into our HHA s own assessment A5 We have posted the OASIS data set in both PDF format i e read only format and Word format on the OASIS Data Sets page at http www cms hhs gov oasis oasisdat asp Q6 Do you have anything available that would help us integrate the OASIS items into our own assessment A6 The most current version of OASIS will be found on the CMS OASIS website HHAs are required to incorporate the OASIS data items exactly as written into the agency s comprehensive assessment For agencies us
58. g reported information from the recent past also applies to the scoring of anxiety in M0580 and depressive feelings in M0590 Q amp A added 06 05 Q125 M0620 Are the behaviors to be considered in responding to this item limited to only those listed in M0610 A125 No there are behaviors other than those listed in M0610 that can be indications of alterations in a patient s cognitive or neuro emotional status Other behaviors such as wandering can interfere with the patient s ability to reach optimal level of function and the frequency of these should be considered in responding to the item Q126 M0630 At discharge does M0630 pertain to the services the patient has been receiving up to the point of discharge or services that will continue past discharge The psych nurse is the only service being provided A126 OASIS items refer to what is true at the time of the assessment unless a specified time point is noted such as 14 days ago Therefore for the situation described if the psych nurse is the only service provided at the time of the discharge assessment the correct response is yes Note that if the psychiatric nurse discharges on Tuesday but the Physical Therapist does the discharge comprehensive assessment on Wednesday then M0630 at discharge would not reflect the presence of psychiatric nursing services Q amp A edited 06 05 NOTE For OASIS items M0640 M0820 the patient s ability may change as the patient
59. h not about the type of assistance that the patient receives For example a patient living in his her own room would be response 1 Lives alone while a patient sharing a room or studio apartment with someone would be response 2 With spouse or significant other or 4 With a friend Q57 M0340 My patient lives alone Monday through Friday but has hired help to stay with her on the weekend how should respond to this item A57 Weekend help would be considered intermittent help according to the item by item tips found in Chapter 8 of the OAS S User s Manual Therefore the correct response in this situation would be 1 Lives alone Q58 M0350 How should we respond to M0350 for patients living in an Assisted Living Facility ALF A58 Rules for licensing Assisted Living Facilities ALFs vary from State to State and the actual physical structural arrangements vary from one facility to another so the answer must be selected that is most appropriate for the individual situation Most patients in an ALF are receiving paid help at least 3 under M0350 although they may also be receiving help from others listed We cannot think of any instances in which a resident of an ALF would be receiving help classified as None of the above 4 under M0350 Refer to the explanation for this item in the OASIS User s Manual Chapter 8 available at http Awww cms hhs gov oasis usermanu asp Q59 M0350 Is Meals on Wheels considered as
60. he ADL IADL OASIS items the patient s ability to perform the tasks is the focus of the assessment The frequency of leaving the home to shop or the amount of effort needed two criteria often associated with homebound status are not the assessment focus here You should provide information in the clinical record to document homebound status regardless of your response to the OASIS items Q161 M0780 Do you consider medications given through a gastrostomy tube M0780 oral medications A161 Item M0780 is assessing the patient s ability to take all oral medicines The route of administration for medications given taken by G tube is per G tube not po Therefore medications whose route is listed as per G tube are NOT oral medications Q162 M0780 My patient sets up her own pill planner How would answer M0780 A162 If your patient is able to take the correct medication in the correct dosage at the correct time as a result of this set up then you would consider her independent and response 0 would apply If your patient relies on a list of medications created by another person to set up her pill planner response 1 would be more appropriate If the patient follows a list that she made herself she is independent and response 0 would apply Q163 M0780 have had several patients who use a list of medications to self administer their meds Would this be considered a drug diary or chart A168 Yes this is considered a drug di
61. he pressure ulcer at its worst prior to healing If the ulcer was a Stage 1 or 2 prior to healing then the updated guidance included in the response to Q97 above should be followed The stage of this newly deteriorated pressure ulcer must be determined based on the current visual assessment by a Clinician skilled in this clinical practice If the ulcer was a Stage 3 or 4 at its worst prior to healing then the ulcer s stage will be reported according to what it was at its worst If the ulcer is worse now the ulcer s stage at its worst i e its current stage also is what will be reported Q amp A added 06 05 Q100 M0468 M0476 Would an arterial ulcer be considered a stasis ulcer A100 No because venous stasis ulcers and arterial ulcers are unique disease entities Refer to the WOCN web site http www wocn org for Clinical Fact Sheets regarding the assessment of leg ulcers information on arterial insufficiency and information on venous insufficiency stasis Q101 M0468 M0476 How can determine whether the patient s ulcer is a stasis ulcer or not A101 The patient s physician is the best information source regarding the root cause of the ulcer Refer to the WOCN web site htto www wocn org for Clinical Fact Sheets regarding the assessment of leg ulcers information on arterial insufficiency and information on venous insufficiency stasis Q102 M0482 M0488 Is a gastrostomy that is being allowed to close on its own co
62. her response 0 or response 1 is appropriate If the patient is never short of breath then response 0 applies If the patient only becomes short of breath when engaging in physically demanding transfer activities then response 1 seems most appropriate In the case of the bedbound patient the level of exertion that produces shortness of breath should also be assessed The examples of exertion given for responses 2 3 and 4 also provide assessment examples Response 0 would apply if the patient were never short of breath Response 1 would be most appropriate if demanding bed mobility activities produce dyspnea Q114 M0500 How should respond to M0500 for the patient receiving Bi PAP not CPAP as included in response 3 A114 If the patient s only respiratory treatment is Bi PAP the appropriate response is 4 None of the above Note that the Response specific Instructions for M0500 direct you to exclude any respiratory treatments that are not specifically listed in the item If the patient uses any of the listed treatments the appropriate response s should be noted The use of Bi PAP would be documented in the patient s clinical record Q115 M0510 If a patient develops a UTI while on a prophylactic antibiotic how should respond to M0510 A115 In that circumstance yes would be the most appropriate response Q116 M0510 If a patient had signs and symptoms of a UTI but no prescribed treatment or the treatment ended more than
63. in past 14 days and M0210 Medical Diagnoses for conditions requiring the change A38 For M0200 identify whether any change has occurred in the patient s medical or treatment regimen in the past 14 days Is there a new diagnosis or an exacerbation of an old diagnosis that necessitates a change in the treatment regimen For example has there been a medication dosage change Are therapy services newly ordered as a treatment regimen change Has a regimen change occurred in response to a change in patient health status M0210 then asks what medical diagnosis has necessitated this change in regimen Was the diuretic increased due to an exacerbation of congestive heart failure Was the patient started on insulin due to a new diagnosis of diabetes Q39 M0200 Must the new or changed diagnosis have occurred in the last 14 days A39 M0200 asks about a change in the patient s medical or treatment regimen not about a new or changed diagnosis It is possible that the treatment regimen change occurred because of a new or changed diagnosis but the item only asks about the medical or treatment regimen change occurring within the past 14 days The change may have occurred because of an exacerbation of an existing diagnosis Q40 M0200 If the patient had a physician appointment in the past 14 days or has a referral for home care services does that qualify as a medical treatment regimen change A40 A physician appointment by itself or a r
64. ing software that does not accommodate bolding or underlining for emphasis of words in the same manner as the current OASIS data set capitalizing those words is acceptable We also recommend including the MOxxx numbers when integrating to alert clinicians that the MOxxx labeled items MUST be assessed and completed Ultimately this will minimize delays in encoding due to uncompleted OASIS data items Please refer to Appendix C of the OASIS User s Manual available at http www cms hhs gov oasis usermanu asp for examples of a comprehensive assessment sample clinical records showing an integration of the OASIS data items with other agency assessment items for each time point The OASIS data sets are available in Appendix B in the OASIS User s Manual or on the OASIS Data Sets page at http www cms hhs gov oasis oasisdat asp Q7 Is there a separate OASIS admission form that can be used for rehab only cases where skilled nursing is not involved A7 The sample assessment forms incorporating OASIS items found on the OASIS Data Sets page http www cms hhs gov oasis oasisdat asp most closely resemble nursing assessments CMS does not have sample rehab assessment examples though such assessments have been developed by commercial vendors If an agency chooses to develop its own rehab specific assessment forms the principles for documenting OASIS items into an agency s clinical documentation are outlined in Chapters 4 and 7 of the OASIS User s Manua
65. is after the clinician has submitted the assessment should M0090 be the date that the clinician completed gathering the assessment information or the date the ICD 9 CM code is assigned A17 The HHA has the overall responsibility for providing services assigning ICD 9 CM codes and billing CMS expects that each agency will develop their own policies and procedures and implement them throughout the agency in a manner that allows for correction or clarification of records to meet professional standards It is appropriate for the clinician to enter the medical diagnosis on the comprehensive assessment The HHA can assign a qualified coder to determine the correct code based upon the written diagnosis The date at M0090 Date Assessment Completed should reflect the actual date the assessment is completed by the qualified clinician If agency policy allows the assessment to be performed over more than one visit the date of the last visit when the assessment is finished is the appropriate date to record Q amp A added 06 05 Q18 M0090 Should the date in M0090 reflect the date that a supervisor completed a review of the assessment A18 While a thorough review by a clinical supervisor may improve assessment completeness and data accuracy the process for such review is an internal agency decision and is not required The assessment completion date to be recorded in M0090 should be the date the actual assessment of the patient was completed Q
66. itted M0890 M0895 and M0900 according to the web site information Yet when a clinician answers hospital for M0855 on the Discharge form she is directed to skip to M0890 which is not included What should happen in this scenario A14 Because your agency has a separate clinical form for Transfer to Inpatient Facility the clinician should NOT be marking hospital on the Discharge form for M0855 because a discharge assessment is not correct at the time of transfer Instead the clinician should be using the Transfer form which will direct her him from M0855 to M0890 when hospital is marked on that form M0890 M0895 and M0900 are all included in the Transfer data items For HHAs with separate Transfer and Discharge forms the only correct response to M0855 on the Discharge form is NA No inpatient facility admission This is an excellent training reminder to share with your staff Q15 Was OASIS item M0160 Financial Factors eliminated If so does this mean that this item was not weighted heavily in the risk adjustment formulas It appears that financial factors would seriously affect outcomes A15 M0160 was required to be collected since OASIS was implemented but the responses to this item never have been transmitted to the State Because the data have never been transmitted there was no way that they could enter into the data analysis and risk adjustment processes Therefore a CMS decision was made to eliminate
67. l available at http www cms hhs gov oasis usermanu asp Q8 The start of care SOC version of OASIS posted on the OASIS web site shows the description of M0550 with two definers a and b However the Discharge and Transfer versions do not show both definers Should the definers be included at all assessment time points A8 The a definer related to an inpatient stay is specific to SOC or resumption of care after an inpatient stay It is not appropriate for the Discharge and Follow up and therefore is omitted from those time point versions This data item also is not included in the Transfer assessment Q9 Are the OASIS data sets all time points to become part of the patient s record Do we keep them in the charts Of course our admission OASIS data set will be part of the chart because we have our admission assessment included in the OASIS questions But with the ROC Transfer DC do we make this part of the record A9 The Comprehensive Assessment Final Rules published January 25 1999 state that the OASIS data items are to be incorporated into the HHA s own assessments not only for the start of care but for all the time points at which an update of the comprehensive assessment is required Because all such documentation is part of the patient s clinical record it follows that the OASIS items are also part of the clinical record Verifying the accuracy of the transmitted OASIS data part of the condition of participation CoP
68. limits or restricts their activity in order to remain pain free A72 Yes a patient who restricts his her activity to be pain free does indeed have pain interfering with activity Since M0420 reports the frequency that pain interferes with activity not the presence of pain itself then M0420 should be scored to reflect the frequency that the patient s activities are affected or limited by pain even if the patient is pain free at present due to the activity restriction Q amp A added 06 05 Q73 M0420 A patient takes narcotic pain medications continuously and is currently pain free Medication side effects including constipation nausea and drowsiness affect the patient s interest and ability to eat walk and socialize Is pain interfering with the patient s activity A73 M0420 identifies the frequency with which pain interferes with a patient s activities taking into account any treatment prescribed If a patient is pain free as a result of the treatment M0420 should be answered to reflect the frequency that the patient s activities are affected or limited by pain In this scenario the patient is described as being pain free but also is described as having medication side effects that interfere with activity Medication side effects are not addressed in responding to M0420 and given the information in the scenario pain apparently is not interfering with the patient s activity Q amp A added 06 05 Q74 M0430 Our agen
69. ling situations and can be found in the Medicare Claims Processing Manual Go to http www cms hhs gov manuals 104 _ claims clm104c10 pdf scroll to page 89 of the document to read Section 80 special Billing Situations Involving OASIS Assessments Questions related to this document must be addressed to your RHHI Q29 M0150 Which pay sources should be noted when responding to M0150 current payment sources for home care A29 All current pay sources should be noted when responding to this item regardless of whether the pay source is primary or secondary If Medicare and other pay source s are paying for care provided by a single agency all the relevant pay sources should be noted Note that the text of M0150 contains the instruction Mark all that apply Q30 M0175 If the patient has outpatient surgery within the 14 day time frame described in M0175 should 1 or NA be marked A30 The correct response would be NA for M0175 because the patient s status would have been an outpatient for this situation Q31 M0175 For M0175 what is the difference between response 3 skilled nursing facility and response 4 other nursing home A31 A skilled nursing facility response 3 means a Medicare certified nursing facility where the patient received a skilled level of care under the Medicare Part A benefit Other nursing facilities response 4 include intermediate care facilities for persons with mental retardation ICF MR and nursing fa
70. ls on day 50 of the episode but we cannot schedule an RN until day 51 of the episode how do we respond to M0903 and M0906 A190 If the agency policy is to have an RN complete the comprehensive assessment in a therapy only case the RN can perform the discharge assessment after the last visit by the SLP This planned visit should be documented on the Plan of Care The RN visit to conduct the discharge assessment is a non billable visit M0903 Date of Last Most Recent Home Visit would be the date of the last visit by the agency in this case it would be the date of the RN visit The date for M0906 Discharge Transfer Death Date would be determined by agency policy The date of the actual agency discharge date would be entered here When the agency establishes its policy regarding the date of discharge it should be noted that a date for M0906 Discharge Transfer Death Date that precedes the date in M0903 Date of Last Most Recent Home Visit would result in a fatal error preventing the assessment from being transmitted Q amp A added 06 05 Q191 M0906 My patient died at home 12 01 after the last visit of 11 30 I did not learn of her death until 12 04 How do complete M0903 and M0906 What about M0090 A191 You will complete an agency discharge for the reason of death at home RFA 8 for M0100 M0090 would be 12 04 the date you learned of her death M0903 date of last home visit would be 11 30 and M0906 death date would be 12 01
71. n scale lichenification changes in shape of the skin surface e g cyst nodule edema breaks in skin surfaces e g abrasion excoriation fissure incision or vascular lesions e g petechiae ecchymosis Q80 M0440 Is a pacemaker considered a skin lesion A80 A pacemaker itself is an implanted device but is not an implanted infusion or venous access device The current surgical wound or healed scar created when the pacemaker was implanted is considered a skin lesion Q81 M0440 How should M0440 be answered if the wound is not observable A81 For the OASIS items a nonobservable wound is one that is covered by a nonremovable dressing or in the case of pressure ulcers an ulcer that is partially or entirely covered by eschar If you know from referral information communication with the physician etc that a wound exists under a nonremovable dressing then the wound is considered to be present and M0440 would be answered Yes Q82 M0440 Is a new suprapubic catheter new PEG site or a new colostomy considered a wound or lesion A82 A new suprapubic catheter site cystostomy new PEG site gastrostomy and a new colostomy have one thing in common they all end in ostomy All ostomies whether new or long standing are excluded from consideration in responding to M0440 Therefore none of these would be considered as a wound or lesion Q83 M0440 How should M0440 be answered if the wound lesion is a burn
72. nced dead on arrival by the ER physician on arrival at the ER is considered to have passed away while under the care of the agency and would be considered to have died at home This patient would have a death at home assessment completed which does not require M0830 Q amp A added 06 05 Q179 M0830 If a patient is admitted to an inpatient facility after initial access in the emergency room can there be a situation in which that emergent care would NOT be reported on M0830 i e patient is only briefly triaged in ER with immediate and direct admit to the hospital A179 The item by item response specific instructions in Chapter 8 of the Implementation Manual clarify that responses to M0830 Emergent Care include the entire period since the last time OASIS data were collected including current events Any access of emergent care regardless of how brief the encounter should be reported on M0830 if it occurred since the last time OASIS data were collected Q amp A added 06 05 Q180 M00830 A patient whose Start of Care is January 9 has an emergent care visit on January 13 that does not result in hospitalization The patient is subsequently recertified and discharged on March 17 M0830 which appears on the transfer and discharge assessments specifies the response should be based on the last time OASIS data was collected Should the response to M0830 regarding emergent care be based on the last time any OASIS assessment wa
73. nsidered a surgical wound A102 A gastrostomy that is being allowed to close would be excluded from consideration as a wound or lesion M0440 meaning that it could not be considered as a surgical wound However the take down of an ostomy done as a surgical procedure would result in both a wound lesion yes to M0440 and a surgical wound yes to M0482 Q103 M0482 If the patient had a port a cath but the agency was not providing any services related to the cath and not accessing it would this be coded as a skin lesion A103 For M0440 you would answer YES for a lesion At M0482 response 1 Yes is appropriate The port a cath or mediport site is considered a surgical wound even if healed over The presence of a wound or lesion should be documented regardless of whether the home care agency is providing services related to the wound or lesion Q104 M0482 Are implanted infusion devices or venous access devices considered surgical wounds Are these included in the count of surgical wounds Does it matter whether or not the device is accessed routinely A104 Yes the surgical sites where such devices were implanted would be considered surgical wounds and included in the total number of surgical wounds at M0484 It does not matter whether the device is accessed at a particular frequency or not Q105 M0482 If debridement is required to remove debris or foreign matter from a traumatic wound is the wound considered a surgical wound
74. ntegrate the OASIS data items into their own assessment instrument in the sequence presented on the OASIS data set for efficiency in data entry we are not precluding them from doing so in a sequence other than that presented on the OASIS data set Agencies collecting data in hard copy or electronic form must incorporate the OASIS data items EXACTLY as they are written into their own assessment instrument Agencies must carefully consider any skip instructions contained within the questions in the assessment categories and provide the proper instructions When agencies encode the OASIS data they have collected data MUST be transmitted in the sequence presented on the OASIS data set The software that CMS has developed for this function HAVEN prompts the user to enter data in a format that will correctly sequence the item responses and ultimately be acceptable for transmission HAVEN includes certain editing functions that flag the user when there is missing information or a question as to the accuracy or validity of the response Agencies may choose to use software other than HAVEN to report their data so as long as the data are ultimately presented to the State agency in the required CMS data submission format found on the CMS Website at http www cms hhs gov oasis datasubm asp This file that contains the OASIS data items in the same order as contained on the OASIS data set Q4 Are any quality assurance tools available to help us verify that our sta
75. o bathe in the tub or shower e g response 4 regardless of the specific cause or barrier preventing the patient from bathing in the shower or tub Q amp A added 06 05 Q141 M0670 Since the transfer into out of the tub shower should not be considered when responding to M0670 is it acceptable for assessing clinicians to ignore Response 2 b from the item wording A141 The tub or shower transfer should not be considered when responding to M0670 and if the transfer is the only bathing task for which a patient requires help to bathe safely in the tub shower then the patient should be scored a 0 or 1 depending on his her need for devices to safely perform all the included bathing tasks independently Q amp A added 06 05 Q142 M0680 If my patient has a urinary catheter does this mean he is totally dependent in toileting A142 M0680 does not differentiate between patients who have urinary catheters and those who do not The item simply asks about the patient s ability to get to and from the toilet or bedside commode This ability can be assessed whether or not the patient uses the toilet for urinary elimination Q143 M0680 If the patient can safely get to and from the toilet independently during the day but uses a bedside commode independently at night what is the appropriate response to this item A143 If the patient chooses to use the commode at night possibly for convenience reasons but is able to get to the bathroom th
76. o break down due to pressure A94 If a pressure ulcer is closed with a muscle flap the new tissue completely replaces the pressure ulcer In this scenario the pressure ulcer goes away and is replaced by a surgical wound If the muscle flap healed completely but then began to break down due to pressure it would be considered a new pressure ulcer If the flap had never healed completely it would be considered a non healing surgical wound Q95 M0445 M0464 If a pressure ulcer is debrided does it become a surgical wound as well as a pressure ulcer A95 No as debridement is a treatment procedure applied to the pressure ulcer The ulcer remains a pressure ulcer and its healing status is recorded appropriately based on assessment Q96 M0445 M0464 If a single pressure ulcer has partially granulated to the surface leaving the ulcer open in more than one area how many pressure ulcers are present A96 Only one pressure ulcer is present The healing status of the pressure ulcer for M0464 can be described by applying the OAS S Guidance Document developed with CMS by the Wound Ostomy and Continence Nurses Society WOCN found at http Awww wocn org Other objective parameters such as size depth drainage etc should also be documented in the clinical record The National Pressure Ulcer Advisory Panel web site http Avww npuap org has valuable information and teaching tools regarding pressure ulcers documenting healing treatment
77. o get to the tub or shower While this may appear to penalize the patient whose tub or shower is on another floor it is within this same environment that improvement or decline in the specific ability will subsequently be measured Q135 M0670 How should I respond to this item for a patient who is able to bathe in the shower with assistance but chooses to sponge bathe independently at the sink A135 The item addresses the patient s ability to bathe in the shower or tub regardless of where or how the patient currently bathes If assistance is needed to bathe in the shower or tub then the level of assistance needed must be noted and response 1 2 or 3 should be selected Q136 M0670 Should the clinician consider the patient s ability to perform bathing related tasks like gathering supplies preparing the bath water shampooing hair or drying off after the bath in responding to this item Q136 When responding to M0670 only the patient s ability to wash the entire body should be considered Bathing related tasks such as those mentioned should not be considered in scoring this item Q amp A added 06 05 Q137 M0670 If a patient can perform most of the bathing tasks i e can wash most of his her body in the shower or tub using only devices but needs help to reach a hard to reach place would the response be 1 because he she is independent with devices with a majority of bathing tasks Or is he she a 2
78. or SQ injection given over a 10 minute period count as an infusion A47 No this injection does not count as infusion therapy Q48 M0250 If the patient refuses tube feedings does this count as enteral nutrition A48 Because the patient is not currently receiving enteral nutrition response 3 would not be appropriate at the time of the assessment The refusal of the tube feedings would be noted in the clinical record Flushing the feeding tube does not provide nutrition Q49 M0250 If the caregiver provides the enteral nutrition independently should response 3 be marked or does the HHA need to provide the care A49 M0250 simply asks about therapies the patient is receiving at home Since this patient is receiving enteral nutrition at home response 3 should be marked Q50 M0250 Do therapies provided in the home have to be documented in the clinical record A50 It seems clear that any of the therapies identified in M0250 IV infusion therapy parenteral nutrition enteral nutrition would be acknowledged in the comprehensive assessment and be noted in the plan of care Even if the family or caregiver manages the therapies completely independently the clinician is likely to evaluate the patient s nutritional or hydration status signs of infection etc It is difficult to conceive of a situation where the answer to this question would be no Q51 M0250 Does M0250 relate to other OASIS items A51 Note
79. ords the severity indices The clinician should write in the medical diagnosis requested in M0210 M0230 M0240 and M0245 if applicable A coding specialist in the agency may enter the actual ICD codes once the assessment is completed The HHA has the overall responsibility for providing services assigning CD 9 CM codes and billing It is expected that each agency will develop their own policies and procedures and implement them throughout the agency that allows for correction or clarification of records to meet professional standards It is prudent to allow for a policy and procedure that would include completion or correction of a clinical record in the absence of the original clinician due to vacation sick time or termination from the agency Q37 M0190 M0210 What is the difference between M0190 and M0210 A37 M0190 and M0210 refer to two separate situations M0190 relates to a patient who has been discharged from an inpatient facility within the past 14 days and reports the diagnoses for conditions that were treated during the inpatient facility stay M0210 relates to a change in the patients medical or treatment regimen during the same past 14 days The diagnoses in the two items may be the same but there is no requirement that they be identical For a patient who was not discharged from an inpatient facility during the past 14 days M0190 would be skipped Q38 M0200 M0210 Please clarify M0200 Medical or Treatment Regimen Change with
80. ospital unit would not be reported as emergent care on M0830 This situation would however be considered a transfer to an inpatient facility as long as the admission lasted 24 hours or longer for reasons other than diagnostic testing and would be considered an emergent reason for hospital admission in responding to M0890 Q amp A added 06 05 Q182 M0855 For M0855 are Rehabilitation Facility and Nursing Home both considered skilled nursing facilities A182 For M0855 response 2 rehabilitation facility is a certified distinct rehabilitation unit of a nursing home OR a freestanding rehabilitation hospital For response 3 nursing home includes either a skilled nursing facility or an intermediate care facility Q183 M0855 A patient receiving skilled nursing care from an HHA under Medicare is periodically placed in a local hospital under a private pay arrangement for family respite The hospital describes this bed as a purely private arrangement to house a person with no skilled services This hospital has acute care swing bed and nursing care units The unit where the patient stays is not Medicare certified Should the agency do a transfer and resumption of care OASIS How should the agency respond to M0100 and M0855 A183 Yes if the patient was admitted to an inpatient facility the agency will need to contact the inpatient facility to verify the type of care that the patient is receiving at the inpatient facilit
81. out preventing it include if pain causes the activity to take longer to complete results in the activity being performed less often than otherwise desired by the patient or requires the patient to have additional assistance Q amp A added 06 05 Q71 M0420 If a patient uses a cane for ambulation in order to relieve low back pain does the use of the cane equate to the presence of pain interfering with activity A71 lf use of the cane provides adequate pain relief that the patient can ambulate in a manner that does not significantly affect distance or performance of other tasks then the cane should be considered a non pharmacological approach to pain management and should not in and of itself be considered as an interference to the patient s activity However if the use of the cane does not fully alleviate the pain or pain effects and even with the use of the cane the patient limits ambulation or requires additional assistance with gait activities then activity would be considers as affected or interfered with by pain and the frequency of such interference should be assessed when responding to M0420 Q amp A added 06 05 Q72 M0420 Would a patient who restricts his her activity i e doesn t climb stairs limits walking distances in order to be pain free thus be considered to have pain interfering with activity And if so would the clinician respond to M0420 based on the frequency that the patient
82. owed by the last four digits of the current Medicare provider number ending with the three digit CMS assigned branch number Q6 M0030 Is the start of care date M0030 the same as the original start of care when the patient was first admitted to the agency or is it the start of care for the current certification period A6 The start of care date M0030 is the date when the patient was admitted to the agency and continues until the patient is discharged It should correspond to the start of care date used for other documentation including billing or physician orders Q7 M0030 What if a new service enters the case during the episode Does it have a different SOC date A7 There is only one Start of Care date for the episode which is the date of the first billable visit Q8 M0032 How should resumption of care ROC be documented if it occurred in a previous 60 day episode certification period What if the latest resumption of care ROC was in a previous 60 day episode A8 The most recent ROC should be documented even if it was in a previous 60 day payment episode as long as the patient has not been discharged from the agency since the most recent ROC Q9 M0040 On M0040 the manual lists the name requirement as First MI Last Suffix but the HAVEN software requires Last First Ml Suffix Can we change the order on our forms to match the software AQ Yes Q10 M0063 If the patient has Medicare but Medicar
83. patient is on a regular bowel program The patient s elimination status must be completely evaluated as part of the comprehensive assessment and the OASIS items answered with the specific findings for the patient The bowel program including the overall approach specific procedures time intervals etc should be documented in the patient s clinical record Q123 M0550 If a patient with an ostomy was hospitalized with diarrhea in the past 14 days does one mark Response 2 to M0550 A123 Response 2 is the appropriate response to mark for M0550 in this situation By description of the purpose of the hospitalization the ostomy was related to the inpatient stay Q124 M0570 If a patient has experienced episodes of recent confusion but does not demonstrate or report any episodes of confusion today the date of the assessment would the patient be considered never confused Or should the recent history of confusion be considered when responding to M0570 A124 Information collected from patient or caregiver report can be utilized in responding to M0570 This includes reports that extend beyond the day of the assessment into the recent past Therefore if the patient or family reported that the patient has experienced periods of confusion on awakening a few mornings over the last week it would be appropriate to mark 2 on awakening or at night only for M0570 even if no confusion was experienced today This same strategy of utilizin
84. reatment etc Q91 M0450 M0464 At M0450 M0464 should we document a pressure ulcer when its stage or status worsens A91 Absolutely If a pressure ulcer worsens in stage or if its status worsens this information should be noted in M0450 through M0464 Q92 M0450 M0464 How can one OASIS tell whether a pressure ulcer has improved A92 The OASIS items are used for outcome measurement and risk factor adjustment There are NO outcome measures computed for pressure ulcer improvement Descriptive documentation in the patient s clinical record should address changes in pressure ulcer size and status that show improvement The National Pressure Ulcer Advisory Panel web site http www npuap org has valuable information and teaching tools regarding pressure ulcers documenting healing treatment etc Q93 M0445 M0464 How should these items be answered if a pressure ulcer is completely healed A93 The healing of a pressure ulcer is never indicated by reverse staging of the ulcer If this were the only ulcer the patient had the appropriate responses would be M0440 yes and M0445 yes M0450 would be answered by indicating the stage of the healed pressure ulcer at its worst with M0460 answered accordingly On OASIS item M0464 the best possible answer for a healed pressure ulcer would be fully granulating Q94 M0445 M0464 If a Stage 3 pressure ulcer is closed with a muscle flap what is recorded What if the muscle flap begins t
85. rvention utilized to defer incontinence If at discharge the patient was dependent on a timed voiding program to defer incontinence the appropriate response to M0520 would be 1 patient is incontinent followed by response 0 to M0530 timed voiding defers incontinence Q amp A added 06 05 Q120 M0530 How should I respond to M0530 for the patient with an ureterostomy A120 If the patient had an ureterostomy M0520 should have been answered with response 0 no incontinence or catheter From response 0 directions are to skip M0530 You should not be responding to M0530 if the patient has an ureterostomy Q121 M0530 If patient had stress incontinence during the day that was not deferred by timed voiding how would M0530 be completed A121 Response 2 at M0530 is the only response that includes the time period of day Therefore that response would be the appropriate one to mark If there were a caregiver he she might consider timed voiding measures to assist in deferring the patient s incontinence during the day Q122 M0540 How should you respond to this item if the patient is on a bowel training program How would that be documented in the clinical record A122 A patient on a regular bowel evacuation program most typically is on that program as an intervention for fecal impaction Such a patient may additionally have occurrences of bowel incontinence but there is no assumed presence of bowel incontinence simply because a
86. s completed or should it be based on the last assessment where M0830 appears In this scenario the item is being asked at the time of discharge where the recertification OASIS was the last time OASIS data was collected Since the emergent care visit occurred before the recertification it would not have been identified at that time because it is nota required item A180 The above scenario does not tell us when recertification assessment was completed According to the Conditions of Participation for HHA the recertification visit should have occurred during a five day period prior to the end of the episode which should be March 5 9 The OASIS item M0830 Emergent Care asks for responses to include the entire period since the last time OASIS data were collected including current events Since the last time OASIS data were collected was at the recertification assessment the emergent care visit occurred prior to that date The correct response to M0830 is 0 no emergent care services were provided Q amp A added 06 05 Q181 M0830 Is M0830 limited to the service sites specifically listed in the OASIS responses What if a patient was a direct admit to the hospital unit without passing through the emergency room A181 M0830 identifies whether the patient received an unscheduled visit to any of the following services hospital emergency room doctor s office house call or outpatient department or emergency clinic A direct admit to a h
87. s condition improves or declines as medical restrictions are imposed or lifted or as the environment is modified The clinician must consider what the patient is able to do on the day of the assessment If ability varies chose the response describing the patient s ability more than 50 of the time See the OASIS User s Manual page 8 89 for more details Q127 M0640 M0800 At OASIS items M0640 M0800 what does IADL mean and what s the difference between IADLs and ADLs A127 ADL stands for activities of daily living while IADL stands for instrumental activities of daily living ADLs refer to basic self care activities e g bathing dressing toileting etc while IADLs include activities associated with independent living necessary to support the ADLs e g use of telephone ability to do laundry shopping etc There is a more complete discussion of this topic in the OASIS User s Manual Chapter 8 Item by Item tips on the page preceding the tips for items M0640 M0800 Q128 M0640 M0800 With regard to the start of care data set what time frame do we select for IADL s ADL s if we are to complete prior 14 days before start of home care and the patient was in the hospital at that time Is this 14 days prior to the hospitalization or 14 days before start of care which would be while the patient was in the hospital A128 For M0640 M0800 the time frame for the prior ADL IADLs should reflect the 14th day directly befor
88. sistance for M0350 A59 M0350 is asking the clinician to identify assisting person s other than home care agency staff Response 3 paid help includes all individuals who are paid to provide assistance to the patient whether paid by the patient family or a specific program Meals on Wheels is a community based service that assists the homebound by delivering meals and would be included in responding to M0350 Q amp A added 06 05 Q60 M0360 How should we respond to OASIS item M0360 for patients living in an Assisted Living Facility ALF A60 Rules for licensing ALFs vary from State to State and the actual physical structural arrangements vary from one facility to another so the answer must be selected that is most appropriate for the individual situation The clinician making the assessment will need to determine who the primary caregiver is and mark the appropriate response under M0360 and continue through the remaining items pertaining to the assistance provided by the primary caregiver Refer to the explanations for these items in the OASIS User s Manual Chapter 8 available at http Awww cms hhs gov oasis usermanu asp Q61 M0360 How should the item be answered if one person takes the lead responsibility but another individual helps out most frequently A61 The clinician should assess further to determine whether one of these individuals should be designated as the primary caregiver or whether response 0 No one person is
89. the item effective December 2002 Eliminating the item from OASIS does not mean it is not important information to consider in care planning agencies may choose to include information about financial factors in their agency specific comprehensive assessment Q16 Please explain the skip patterns related to pressure ulcers and stasis ulcers for OASIS items M0460 M0478 M0488 and M0530 at follow up RFA 4 5 What do you fill in and what do you skip A16 The skip patterns were modified only for the follow up recertification time points RFAs 4 and 5 due to the changes in the required data items for those assessments based on industry requests effective December 2002 There were no changes to the skip patterns associated with these items for Reason for Assessments RFAs 1 3 6 7 8 and 9 At the recertification or other follow up time points M0460 can be skipped if the patient has no pressure ulcer M0476 can be skipped if the patient has no stasis ulcer M0488 can be skipped if the patient has no surgical wound and M0530 can be skipped if the patient has no urinary incontinence or has a urinary catheter In designing their clinical documentation for these time points agencies should pay very close attention to these skip patterns Agencies may choose to retain all of the wound and urinary continence items in their forms Non required items submitted will not be stored on the State s database Q17 Unless otherwise indicated scoring of OAS
90. these dates are likely to be different These situations are 1 transfer to an inpatient facility 2 patient death at home and 3 the situation of an unexpected discharge In these situations the M0090 date is the date the agency learns of the event which is not necessarily associated with a home visit M0903 must be the date of an actual home visit See the OASIS User s Manual Chapter 4 for additional information on unexpected discharges Q189 M0903 What constitutes a home visit when responding to OASIS Item M0903 Medicaid programs pay for some home health services provided outside of the home If these patients receive all their skilled care outside the home must OASIS data be collected and transmitted If some of the visits are provided outside of the home should a visit provided outside the home be considered the last visit for M0903 or should M0903 be the last visit at the patient s home A189 The date of the last most recent home visit for responding to M0903 is the last visit occurring under the plan of treatment The HHA must conduct the comprehensive assessment and collect and transmit OASIS items for Medicaid patients receiving skilled care Q amp A added 06 05 Q190 M0903 M0906 When a speech therapist is the last service in a patient s home our agency has chosen to use an RN to complete the discharge assessment with OASIS as a non billable visit If the patient meets the speech therapist s goa
91. to and out of tub or shower Pushing up with both arms could apply to two of these transfer types bed to chair and on off toilet or commode Taking extra time and pushing up with both arms can help ensure the patient s stability and safety during the transfer process but does not mean that the patient is not independent If standby human assistance were necessary to assure safety then a different response level would apply to these types of transfers Remember that transfer ability can vary across these three activities The level of ability applicable to the majority of the activities should be recorded Q152 M0700 What if my patient has physician ordered activity restrictions due to a joint replacement What they are able to do and what they are allowed to do may be different How should I respond to this item A152 The patient s medical restrictions must be considered in responding to the item as the restrictions address what the patient is able to safely accomplish at the time of the assessment Q153 M0700 Does M0700 include the ability to use a powered wheelchair or only a manual one A153 The OASIS item does not differentiate between the ability to use a powered wheelchair or a manual one Q154 M0700 If a patient uses a wheelchair for 75 of their mobility and walks for 25 of their mobility then should they be scored based on their wheelchair status because that is their mode of mobility gt 50 of the time Or should
92. to enable the new agency to bill for the patient s care Q23 M0100 A patient receiving skilled nursing care from an HHA under Medicare is periodically placed in a local hospital under a private pay arrangement for family respite The hospital describes this bed as a purely private arrangement to house a person with no skilled services This hospital has acute care swing bed and nursing care unit The unit where the patient stays is not Medicare certified Should the agency do a transfer and resumption of care OASIS How should the agency respond to M0100 and M0855 A23 Yes if the patient was admitted to an inpatient facility the best response to M0100 Reason for Assessment RFA is Transfer to an Inpatient Facility Depending on the agency policy the choice may be RFA 6 transfer to an inpatient facility patient not discharged or RFA 7 transfer to an inpatient facility patient discharged The agency will need to contact the inpatient facility to verify the type of care that the patient is receiving at the inpatient facility and determine the appropriate response to M0855 If the patient is using a hospital bed response 1 applies if the patient is using a nursing home bed response 3 applies If the patient is using a swing bed it is necessary to determine whether the patient was occupying a designated hospital bed response 1 applies or a nursing home bed response 3 applies The hospital utilization department should be able to advis
93. uding adding appropriate fluids or medication cleaning storing disposing of equipment and supplies should be assessed NA would not be an appropriate response to M0810 in this situation Q170 M0810 Does this item include delivery devices for inhaled medications TENS units or mechanical compression devices A170 M0810 and M0820 consider management of equipment and supplies only for oxygen IV infusion therapy enteral parenteral nutrition and ventilator therapy and do not include the delivery devices or equipment associated with other treatments such as the type listed Note that inhaled medications are addressed in M0790 Q171 M0820 My patient has a caregiver who does everything but manage the equipment How should answer M0820 A171 This item addresses only the caregiver s ability to manage the specific types of equipment listed Thus your response should reflect only the caregiver s ability in this particular aspect of care The item is very circumscribed to a specific aspect of care and to specific equipment so your response should be confined to only these components of care delivery The other care provided by the caregiver can be recorded in the clinical record in other areas Q172 M0830 When I called to schedule my visit learned that my patient was seen in the ER and was then admitted to the hospital How should answer M0830 A172 Emergent care includes all unscheduled visits to medical services as noted in th
94. y and determine the appropriate response to M0855 If the patient is using a hospital bed response 1 applies if the patient is using a nursing home bed response 3 applies If the patient is using a swing bed it is necessary to determine whether the patient was occupying a designated hospital bed response 1 would apply or a nursing home bed response 3 would apply The hospital utilization department should be able to advise the agency of the type of bed and services the patient utilized Q amp A added 06 05 Q184 M0870 My patient was admitted to the hospital and completed the assessment information for Transfer to the Inpatient Facility His family informed me that he will be going to a nursing home rather than returning home so my agency will discharge him How should complete these items on the discharge assessment A184 Once the transfer information was completed for this patient no additional OASIS data would be required Your agency will complete a discharge summary that reports what happened to the patient for the agency clinical record however no discharge OASIS assessment is required in this case The principle that applies to this situation is that the patient has not been under the care of your agency since the inpatient facility admission Because the agency has not had responsibility for the patient no additional assessments or OASIS data are necessary Q185 M0880 How would outpatient therapy services be categorized

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