Following the release and revision of the draft manual in May 2022, the Centers for Medicare and Medicaid Services (CMS) released the Final OASIS-E Guidance Manual on December 14. The final manual is available for download on the CMS website under the OASIS User Manuals page. Moreover, a log of changes since the last posting is also available.
Has Anything Changed?
Changes to how the assessments are to be completed are not major, such as revisions on some of the actual wording and instructions. There is nothing significant enough to change any education provided for your staff.
On the other hand, there have been multiple updates to the new items in the OASIS-E, these includes:
- Changes to the content of the items and instructions from D0150 and D0160, which is the PHQ2 to PHQ9 assessments for depression.
- Updated language of the instructions and examples for K0520, which is the new item for nutrition, and N0415 for high-risk medication.
- Guidance updates to O0110 that are specific to additional treatments.
- Updated definition of rehabilitation therapy in J0520.
- Revision of some language in C0500 surrounding the use of the dash.
OASIS-E Inclusive Coverage
It is important to note that the effective date for OASIS-E is January 1, 2023, and that the version of OASIS that should be collected will be based on the M0090 – Date Assessment Completed. This means that the M0090 date is the last date that information used to complete the comprehensive assessment and determine OASIS coding is gathered and completed.
This is not “starts of care January 1 or later.” It is any OASIS with a Date the Assessment is Completed of January 1, 2023, or later. You will have some patients with Start of Care (SOC) dates that are done at the end of this year that will be OASIS-D1 and then a transfer, resumption, or discharge that is completed in 2023, and that will be based on the OASIS-E. This is the same as effective dates every time there is a significant update to the OASIS.
CMS made sure to clarify that it is unnecessary to use artificial M0090 dates with this transition to OASIS-E. All assessments with an M0090 – Date Assessment Completed on or before December 31, 2022, including the last 5 days of 2022 must be completed with OASIS-D1. This is true even when the first day of the new certification period is on or after January 1, 2023.
All assessments with an M0090 – Date Assessment Completed on or after January 1, 2023, must be completed with OASIS-E. This is true even when the assessment was initiated in 2022.
Minimize Setbacks on Your OASIS-E Implementation
With the OASIS-E implementation just around the corner, agencies should finalize preparations now to minimize the potential setbacks in the OASIS documentation quality. Agencies should take advantage of the available resources and the final OASIS-E instrument and Guidance Manual to train their clinicians.
While it may take time for clinicians to get everything right with all the new changes in the OASIS-E documentation, it is important to solicit help where it is needed. One way is to collaborate with your QA provider to aid your clinicians in familiarizing themselves with the changes and making sure that new OASIS assessment data are accurately documented. Moreover, you can leverage your QA program to not only maintain compliance, but also to apply new efforts to continue to optimize your reimbursements amidst all the changes.