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More OASIS-E Guidance from the January 2023 OASIS Q&As

    The Centers for Medicare & Medicaid Services (CMS) have released the January 2023 OASIS Q&A sessions, which provide guidance on OASIS-E documentation in complex situations. These questions which were received by the CMS help desk from Q4 of 2022 address certain topics about BIMS interview items, mental status, and SDoH, among others. By answering these questions, CMS aims to help clinicians and home health agencies ensure accurate and compliant documentation in the new OASIS-E.

    Here are the most relevant and helpful items from the new set:

    When to use OASIS-D and OASIS-E

    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?


    The effective date for OASIS-E is January 1, 2023. The version of OASIS that should be collected will be based on the M0090 – Date Assessment Completed. The M0090 date is the last date that information used to complete the comprehensive assessment and determine OASIS coding was gathered by the assessing clinician and documentation of the specific responses was completed.

    With this transition to OASIS-E, there is no need for the use of artificial M0090 dates. All assessments with a 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 a 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


    How is “baseline” defined at discharge for C1310A – Acute Onset Mental Status Change? 

    The intent of C1310 – Signs and Symptoms of Delirium is to identify any signs or symptoms of acute mental status changes as compared to the patient’s baseline status.

    As stated in the Coding Instructions for C1310A – Acute Mental Status Change, Code 1, Yes, if patient has an alteration in mental status observed or reported or identified that represents an acute change from baseline. 

    Examples of acute mental status changes:

    • a patient who is usually noisy or belligerent becomes quiet, lethargic, or inattentive
    • a patient who is normally quiet and content suddenly becomes restless or noisy
    • a patient who is usually able to find their way around their living environment begins to get lost.

    At discharge, compare the patient’s current mental status to their baseline mental status (prior to the discharge assessment time period under consideration). 

    J0510, J0520, J0530

    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?

    For the Pain Interview items (J0510, J0520, and J0530) the day of assessment is considered day 0. The time period under consideration or “look back” for the pain interview item includes the day of assessment in addition to looking back over the last 5 days.


    Would an AV fistula be reported in O0110O1 – IV Access?

    An AV fistula does not meet the definition of IV Access for O0110O1. If there is not a current IV access in place at the time of assessment, and no other treatments, programs, or procedures listed in O0110 apply to the patient then code O0110Z – None of the above.

    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?

    The intent of O0110 – Special Treatments, Procedures, and Programs is to identify any special treatments, procedures, and programs that apply to the patient. If there is not a current IV access in place at the time of assessment do not code IV access for O0110O1, even if a treatment which would require an IV access is part of the patient’s current care/treatment plan.

    Maintaining OASIS Accuracy

    The Q&As by CMS provide valuable insights on how to approach the OASIS documentation in various situations. Indeed, OASIS-E requires thorough analysis of each patient case for full compliance.

    Leverage your quality assurance team to review accuracy of OASIS responses especially on items that impact payments. It may take some time for clinicians to get familiar with all the new changes in OASIS-E, hence it would greatly help to have another set of eyes checking your documentation to make sure you maintain compliance and optmize reimbursements.