January 2023 CMS Quarterly OASIS Q&As

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

This morning (January 17, 2023), CMS posted the January 2023 CMS Quarterly OASIS Q&As. This document is intended to provide guidance on OASIS questions that were received by CMS help desks. Responses contained in this document may be time-limited and may be superseded by guidance published by CMS at a later date.

The 6-page Q&A contents includes:

  • Can CMS please provide further guidance on the transition from OASIS-D to OASIS-E. For example, if we initiate an OASIS at the end of 2022 but completed the assessment in 2023 should we be completing OASIS-D or OASIS-E? Does this change if we are recertifying a patient at the end of 2022 and the first day of the new 60-day certification period is in 2023?
  • While configuring the new OASIS-E items in our EMR system, would it be compliant if additional prompts were added to clarify the reason for coding a 0 response for one or more BIMS Interview Items (C0200 – C0400)? The 0 can have different meanings and the reason for coding the 0 may influence the scoring of C0500 – BIMS Summary Score.
  • A number of new items (A1005 – Ethnicity, A1010 – Race, A1110 – Language, A1250 – Transportation) state that a proxy can be used. Who would be considered a proxy? Can it be a caregiver, family member, friend or can it only be the Power of Attorney (POA), or health care representative?
  • For A1110 – Language is it permissible to use a Spanish-speaking clinician as an interpreter?
  • How is “baseline” defined at discharge for C1310A – Acute Onset Mental Status Change?
  • Can you provide additional information on the rationale for having to use multipliers in D0160 – Total Severity Score? When reviewing the Pfizer version of the PHQ-9 scoring, Pfizer does not indicate a process computing scores for missed questions.
  • For the pain interview items, how do we define the term “over the past 5 days”? Does the day of assessment count as day 0 and then you count back, or is the day of assessment considered day 1 and then you count back?
  • If a patient is placed on a full liquid diet for a bowel cleanse should this be considered a mechanically altered diet when coding K0520 – Nutritional Approaches?
  • My question relates to a patient who self identifies as a gender different than that assigned at birth, but who has a disease that is inherent to the gender assigned at birth. Example: patient designated male at birth identifies as a female and has a diagnosis of benign prostatic hypertrophy (BPH). As the patient self-identifies as female, we report 2 – Female for M00069 – Gender. If we also list female as the gender on the claim, the claim is rejected because the diagnosis of BPH is not compatible with the female gender. How should we resolve this situation?
  • For N0415 – High-Risk Drug Classes: Use and Indication can you provide an example of a combination drug that would be in more than one of the listed high-risk drug classes?
  • Are the following scenarios acceptable approaches to determining that a patient-specific indication is documented for N0415 – High-Risk Drug Classes: Use and Indication?    
    • A clinician finds the patient-specific indication noted on the discharge paperwork from the referring facility (e.g., coumadin for afib)
    • There is no patient-specific indication noted for a medication, so the clinician calls the physician to verify why the patient is taking the med and adds the physician response to the HH medical record
    • The patient or family member verbally tells the clinician why the medication is being used (e.g., “for my back pain”, “for my infection”) and the clinician documents this reason in the HH medical record
    • A clinician sees a diagnosis documented in discharge or referral paperwork (e.g., diabetes, schizophrenia) and the patient is taking related medications (e.g., hypoglycemic, antipsychotic) so considers the documented diagnosis as the patient-specific indication.
  • Would an AV fistula be reported in O0110O1 – IV Access?
  • A patient’s current care/treatment plan includes an order for PRN IV Lasix. At the time of the assessment and during the assessment timeframe the patient did not meet the parameters established by the physician to administer the Lasix. We understand that we would check O0110H1 – IV Medications, since the PRN IV Lasix is part of the patient’s current care/treatment plan, even though it is not being received during the assessment timeframe. Would we also report O0110O1 – IV Access, even though the IV Access is not in place or needed during the assessment timeframe?