CMS Publishes Draft of OASIS-D Guidance Manual

When it comes to home health regulations, CMS has been busy little beavers lately. In addition to publishing the proposed 2019 Home Health Proposed Rule, on July 2, 2018 CMS published the draft OASIS-D Guidance Manual found at the bottom of the OASIS User Manuals page. We compared the OASIS-C2 Guidance Manual with the OASIS-D Guidance Manual and have identified several differences. Also, check out our prior article for an overview of the changes in the contents from OASIS-C2 to OASIS-D.

Collaboration

The issue of how clinicians can share information has been answered. The assessing clinician can receive feedback from any other clinician who has had “direct in-person contact with the patient” or have obtained the patient health information from other methods such as “health care monitoring devices, video streaming, review of photograph, phone call, etc.” However, the final response must be chosen by the assessing clinician and the M0090 Date Assessment Completed date must be adjusted to account for the final date information was received. Make sure agency policy allows for clinical collaboration on comprehensive assessments.

Clarification of Verbiage

Some changes are more housekeeping items rather than substantial changes. For example, the response-specific instructions in M0102 now include Resumption of Care (ROC) information even though the question has clearly applied to ROCs all along. “Pressure ulcers” are now clarified to be “pressure ulcers/injuries” to better align with wound care terminology. “Medical records” are now “Clinical records”.

Formatting Changes

The guidance manual places more explanation information into Definition boxes to easily view the intent of the terminology of the questions. General guidance for each item are still located in “Response-Specific Instructions” however, for many of the OASIS questions there is now a sub-section called “Coding Instructions” where criteria is given for each individual answer.

Many of the M-questions now have examples where there weren’t any before. Some pre-existing examples have been expanded upon to further clarify correct responses.

OASIS Question Changes / Clarifications

M1028 now includes “3 – None of the above” for patients who do not have PVD or DM.

M1060 Height and Weight instructions make it clear that data not taken from agency staff measurements is not to be used. If height and/or weight cannot be measured by agency staff, a dash is to be used. But “CMS expects dash use to be a rare occurrence” so make sure your staff has the tools they need to obtain these numbers.

M1306-M1311 in the wound section have a great deal more instruction than the prior manual. What constitutes an “unstageable” ulcer or injury is explained in detail using several examples. Properties for deep tissue injury, eschar, and slough are given to more easily identify them for wound evaluation. Examples are given for several deep tissue injury wound situations and how to address them at discharge.

M2001-M2016 in the drug section of the OASIS expands upon what “by midnight of the next calendar day” means with examples. It also clarifies that “contact with a physician/physician designee” requires communication from the clinician and the corresponding physician or designee response to either acknowledge the information or give instruction on interventions to respond to the identified medication issue.

New OASIS Questions

Finally, the most anticipated updates to the guidance manual occur in Chapter 3 Section GG and Section J. These sections are nicely covered with coding instructions for responses and examples.

Section GG covers functional abilities and goals for the patient. GG0100 covers the patient’s level of function prior to the medical condition that they are currently receiving treatment for. Most of the coding instructions are just a reiteration of the instructions from the question. However, the example is a good illustration of when response “NA” would be used.

Devices used prior to the current treatment diagnoses onset or exacerbation are addressed in GG0110. This section has some good explanations for equipment. For example, a “mechanical lift” could be a stair lift, hoyer lift or bath tub lift, among others. The instructions for this item include patient scenarios as well.

GG0130, Self-Care, is a beast of a question and, as such, has a good amount of explanation. Instructions include strategies on how to assess each of the functional questions as well as how to address discharge goals. For example, it is not necessary to establish a discharge goal for every self-care function. CMS allows a dash response and does not discourage the usage of it within this OASIS question. There is some extra information in the coding instructions for the responses but most of them just restate the original guidance. There are some very nice examples on how to code certain medical scenarios.

GG0170 addresses Mobility in a similar manner to GG0130. This question also allows for a dash response for discharge goal and does not appear to limit or discourage its use other than to say at least one item must have a discharge goal. Limited additional instruction is given for each response. However, the coding tips and examples section thoroughly covers each of the criteria to be assessed giving great relevant clinical examples and assessment strategies.

Section J1800 addresses falls since the most recent SOC/ROC. It clarifies that a fall is an unexpected occurrence even if it is interrupted (called an “intercepted fall”) unless that intercepted fall is part of the therapeutic treatment. There are several examples given to assist the clinician in determining which situations constitute true falls for this response.

J1900 explores the number of falls since SOC/ROC that resulted in injuries and the severity of those injuries. The definitions of the type of injuries are restated from the question. There are several detailed examples that are worth reviewing with your staff.

OASIS-D Revisions Updated

In our previous article covering OASIS-D, we included some drafts to help visualize the changes from OASIS-C2. They contained old data set items in red and new items in green to allow you to see additions and deletions more clearly. In this article, we are presenting OASIS-D data sets according to the draft guidance manual. Though there could be some additional changes before the data set is finalized, we anticipate that those changes will be relatively minor and this is a good start for training clinicians.

• OASIS-D Start of Care / Resumption of Care
• OASIS-D Recertification / Other Follow-Up
• OASIS-D Discharge
• OASIS-D Transfer to Inpatient
• OASIS-D Death at Home

In Summary

The good news is that not a lot has changed in the instructions for many of the existing OASIS questions. Though some sections had minor changes, we recommend that clinical managers and quality improvement personnel review the instructions for all of the OASIS questions because many of the sections instruct on clinical collaboration. If you are pressed for time, the OASIS wound questions (M1306-M1311), drug questions (M2001-M2016) and the new sections GG0100, GG0110, GG0130, GG0170, J1800 and J1900 should be reviewed as soon as possible and education strategies devised for clinical staff who perform the OASIS assessment.

If you are a therapist or nurse who documents the OASIS, don’t wait for your agency to reach out with educational opportunities. We recommend that you review the OASIS instructions and follow up with your home health agency with any questions or concerns. You will ultimately be responsible for the accuracy of your documentation and that includes a thorough understanding of the intent and parameters of each question.