CMS April 2023 Quarterly Home Health Q&As

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

CMS past posted the April 2023 CMS Quarterly OASIS Q&As.  This Q&A is 6 pages in length, addressing 14 questions:

  • Question 1: When did the new risk models for 2023 take effect?
  • Question 2: Are the new items that were added to the OASIS-E instrument being used in the new risk models that took effect 1/1/2023?
  • Question 3: What assessment-based quality measures exclude patients who are transferred or discharged from home health to hospice?
  • Question 4: What patients are excluded from the OASIS-based Discharged to Community measure?
  • Question 5: Please clarify when the entire Patient Mood Interview should be completed for D0150 – Patient Mood Interview (PHQ-2 to 9). The instruction in the OASIS-E Guidance Manual appears to conflict with the language in the D0150 item.
  • Question 6: Should K0520B – Nutritional Approaches; Feeding Tube be checked if there is a feeding tube present, but it is not being utilized for nutritional/hydration purposes? Can K0520B be coded if it is just used to deliver medications?
  • Question 7: Please provide guidance as to the accurate response for K0520Z – Nutritional Approaches; None of the Above in the following scenario: K0520A – Parenteral/IV Feeding = checked K0520B – Feeding Tube = not checked K0520C – Mechanically altered diet = Dash to indicate there was no available information K0520D – Therapeutic diet = not checked Should K0520Z – None be unchecked because K0520A is checked, or dashed because K0520C is dashed?
  • Question 8: What is the look back or time period under consideration for the new OASIS items K0520 – Nutritional Approaches, N0415 – High-Risk Drug Classes: Use and Indication, and O0110 – Special Treatments, Procedures, and Programs? Is it the day of assessment, which may include medications, nutritional approaches, and/or treatments, procedures, or programs the patient may have taken/received in an inpatient facility before they were discharged home, or is coding just based on what is part of the current reconciled drug regimen and/or current care/treatment plan at the time of the assessment?
  • Question 9: Should a symptom control rating be assigned for a code beginning in V, W, X, Y and Z reported in M1021 – Primary Diagnosis or M1023 – Other Diagnoses? The OASIS-D manual guidance specifically stated no, but that statement is no longer in the OASIS-E guidance manual.
  • Question 10: Is there a definition for continuous oxygen use for M1400 – Dyspnea? Does the definition for intermittent and continuous oxygen, used in O0110 – Special Treatments, Procedures, and Programs, apply to M1400 as well?
  • Question 11: If an anticoagulant is used to flush a PICC line that has become blocked with clotted blood, should that anticoagulant be considered when coding N0415 – High-Risk Drug Classes: Use and Indication?
  • Question 12: Please provide guidance on the following scenario. A patient is admitted to a home health agency and then, during the assessment timeframe, goes to the Emergency Department (ED) and receives a one-time dose of a medication that is classified as a medication in the list of high-risk medication for N0415 – High-Risk Drug Classes: Use and Indication. If the Start of Care assessment was not completed until after the patient returned from the ED should the medication that was received in the ED be considered when coding N0415?
  • Question 13: The guidance for O0110H1 – IV Medications includes an exclusion for Dextrose 50% and Lactated Ringers, stating that these are not considered medications. There are references that have both Dextrose 50% and Lactated Ringers listed as medications. Should these be excluded from consideration when coding O0110H1? Should any solution that includes dextrose be excluded from consideration?
  • Question 14: We know that we code O0110 – Special Treatments, Procedures, and Programs based on what is part of the current care/treatment plan at the time of the assessment. Can CMS provide further clarification on how to code O0110O1 – IV Access and O0110O4 – IV Access; Central if a PICC line is being pulled during the discharge assessment?

If you’re interested in past Q&A documents, check out this link.