October 2022 CMS Quarterly OASIS Q&As

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

CMS has posted the 5-page October 2022 Quarterly OASIS Q&Asdocument for Home Health Agencies.

For a sneak preview, here are the questions in this document:

  • Question 1: Please provide guidance on the following scenario: A patient was recertified between days 56-60 and then in the new 60-day certification period, prior to any home health visits being made, the patient is admitted to the hospital for a qualifying inpatient stay. Should the agency complete the RFA 6 – Transferred to an inpatient facility, patient not discharged from agency and a Resumption of Care when the patient returns? Or should an RFA 7 – Transferred to an inpatient facility, patient discharged from agency be completed and a new Start of Care be completed?
  • Question 2: Can information collected prior to Start of Care/Resumption of Care be used to complete the new OASIS items such A1005 – Ethnicity, A1010 – Race, A1110 – Language, A1250 – Transportation, B1300 – Health Literacy, and D0700 – Social Isolation?
  • Question 3: Please provide an example where the coding for A1250 – Transportation and B1300 – Health Literacy would be different from Start of Care/Resumption of Care to Discharge.
  • Question 4: I know we can administer the BIMS either verbally or in writing and there are specific directions around this. When administering the BIMS in writing can we present the cue card questions via laptop rather than an actual paper form for those patients who are hearing impaired etc., or does it need to be given in paper or card format?
  • Question 5: The rehab therapy definition in the draft OASIS-E Guidance Manual states for J0520: Rehab Therapy – special healthcare service or programs that help a person regain physical, mental, and or cognitive (thinking and learning) abilities that have been lost or impaired as a result of disease, injury or treatment. Can include, for example, PT, OT, SP, and cardiac and pulmonary therapies.                                                                                                                                                               

Based on the term “regain,” would maintenance therapy not be considered a rehab therapy for the item J0520 – Pain interference with therapy activities?

  • Question 6: When coding K0520 – Nutritional Approaches should we only consider those nutritional approaches that the patient actually receives at Start of Care/Resumption of Care (SOC/ROC) and discharge or just those that are included on the plan of care? When coding K0520 at discharge should we only indicate those nutritional approaches that the patient will continue to receive after the patient is discharged?
  • Question 7: When determining if a medication should be included in one of the 6 high risk drug classes collected in the new OASIS-E item N0415 – High Risk Drug Classes: Use and Indication, which drug classification system should be used?

Is there a specific drug classification system that should be used, or can clinicians use any authoritative source even if a system describes the drug classes using terminology that differs from the exact drug classes reported in the item?

  • Question 8: If a medication is ordered for the patient to take once they are discharged from the home health agency, should that medication be considered when coding N0415 – High-Risk Drug Classes: Use and Indication at discharge?
  • Question 9: We have a question regarding O0110 – Special Treatments, Procedures, and Programs. Are special treatments, procedures, and programs that the patient was receiving only during the time period under consideration for Start of Care/Resumption of Care (SOC/ROC) or discharge considered? At discharge, should we also consider what the patient has ordered to receive after discharge (e.g., Chemotherapy or radiation scheduled to begin after discharge)?
  • Question 10: For O0110C – Special Treatments, Procedures, and Programs; Oxygen therapy: If the oxygen is ordered PRN, is that considered intermittent because it is ordered PRN or only if the patient uses it PRN on the day of assessment?
  • Question 11: For Special Treatments, Procedures, and Programs: Non-invasive Mechanical Ventilator O0110G2 – BiPAP and O0110G3 – CPAP, are these only selected if the BiPAP/CPAP was used during the assessment window? Sometimes a treatment may be ordered and available but the patient will refuse to wear it.

I encourage you to review and save this document for the answers to these coding questions.

If you’d like to view previous quarterly Q&As, click here then scroll down the webpage to the OASIS Quarterly Q&A’s header. You’ll find documents dating back to January 2013.