October 2021 CMS Quarterly OASIS Q&As

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

CMS has just posted (October 19, 2021) the October 2021 CMS Quarterly OASIS Q&As document.

 This is a 3-page document that addresses 7 specific questions:

  • Question 1: An RN goes to a patient home for an anticipated discharge visit. The patient agrees to discontinuing home care services but declines going through the full assessment of items on the OASIS. May this clinician still complete the discharge OASIS in collaboration with other disciplines that have seen this patient within the past 5 days prior to the date of this visit?
  • Question 2: Historic OASIS guidance directs agencies to complete a transfer OASIS (RFA 7 – Transferred to an inpatient facility – patient discharged from agency) under the following unique circumstances:

• A patient dies less than 24 hours after being admitted to an inpatient facility, or,

• A patient dies in the emergency room (ER), or,

• A patient dies in outpatient surgery.

This means that to meet the new quality measure, Transfer of Health Information to Provider, an agency must send a medication list to the subsequent provider, even for a patient that had died in one of these unique circumstances. Please clarify if this guidance will be modified to accommodate the intent of the Transfer of Health Information to Provider quality measure.

  • Question 3: Please provide clarification on what it means that occupational therapists (OTs) can complete the Start of Care (SOC) OASIS for rehab cases. Does this mean that OT’s establish eligibility for home care services? Are they allowed to be a stand-alone service from the SOC?
  • Question 4: I have a question about the current guidance that states: If a pressure ulcer/injury is surgically closed with a flap or graft, it should be considered a surgical wound and not a pressure ulcer/injury. If the flap or graft fails, it should still be considered a surgical wound until healed.

Is this in reference to ANY point in time that the flap/graft fails? For example, if the area of flap/graft heals and has been 100% re-epithelized for greater than 30 days and a patient subsequently develops a wound at the site of the original flap/graft, would it be considered failed surgical site or would it be considered a pressure ulcer/injury?

  • Question 5: Would a pacemaker or an implantable loop recording device be considered a surgical wound once the initial insertion site has been fully epithelialized for at least 30 days?
  • Question 6: I am looking for clarification on when to code response 4 for M1710 – When Confused and response 3 for M1720 – When Anxious. I know the look back period is the last 14 days however there is no definition for “4 – Constantly” (for M1710) or “3 – All of the time” (for M1720). For “4-Constantly” (M1710) or “3- All the time” (M1720) to be marked, would the patient have to have been confused or anxious for the entire 14 day look back? Or would Constantly or All of the time apply if the patient was confused or anxious for a period of time shorter than the 14 day look back such as for an entire 24-hour period (constantly for at least one day)?
  • Question 7: If a patient is not taking any high-risk medications at home, but goes to an outpatient oncology clinic for chemotherapy infusions how is M2010 – Patient/Caregiver High-Risk Drug Education answered?