The Centers for Medicare & Medicaid Services (CMS) released a new set of quarterly OASIS Q&As that address OASIS questions received by their help desks. The Q&As provide guidance on how to respond to certain M and GG items in complex scenarios.
One of the best ways to prepare for the shift to OASIS-E is to first ensure mastering the transitional aspects of OASIS-D as 75% of the information in OASIS-E is already in OASIS-D1. Training too early for specific OASIS-E items may be in vain, as clinicians will not be putting them into practice for months.
Here are some notable Q&As from the new set:
GG0170M, N & O
Question: What is specifically assessed when a patient uses a stair lift to ascend/descend stairs for GG0170 – Mobility? Should the GG activities be coded based on the type and amount of assistance required to get on and off the stair lift? Or is it the type and amount of assistance required to use the stair lift itself?
Answer: The intent of the GG0170 stair activities is to assess the patient’s ability to go up and down 1 step/curb, 4 steps, and 12 steps. Clinicians should code based on the type and amount of assistance required for the patient to complete the stair activities as independently and safely as possible.
Completing the stair activities indicates that a patient goes up and down the stairs, by any safe means, with or without any assistive devices (including cane, walker, railing, or stair lift) and with or without some level of assistance. Going up and down stairs by any safe means includes the patient walking up and down stairs on their feet or bumping/scooting up and down stairs on their buttocks.
When using a stair lift to ascend/descend stairs code based on the type and amount of assistance the patient requires to ascend/descend stairs beginning once the patient is seated and ending when the patient is ready to transfer out of the seat.
Question: When assessing M2020 – Management of Oral Medications and M2030 – Management of Injectable Medications, please explain what is meant by “routinely stored.” Would this mean where a facility normally stores patient medications, or where the patient would store them if they were at home? For example, a patient with normal cognitive abilities living in an assisted living facility may routinely store their medications in their apartment where they can safely and correctly take their medications. However, because of the patient’s living situation and the Assisted Living Facility (ALF) policy, the medications are stored in a medication room down the hall which is kept locked.
Answer: In the situation where the medications are locked up in the assisted living facility (ALF) nursing office, code based on the patient’s physical and cognitive ability to access the medication from where it is routinely stored, and to take their medications at the right time and in the right dose. Assess the patient’s ability to access medications based on where the medications are routinely stored. If the routine location has been temporarily modified, continue to code based on an assessment of the patient’s ability to access from the location where the medications are routinely stored.
Question: For N0415 – High-Risk Drug Classes: Use and Indication; how specific does the documented indication need to be? When patients receive their medications from the pharmacy, the pamphlets include reasons why the medications are taken. Is this enough or does it need to be more specific than that?
Answer: The intent of N0415 – High-Risk Drug Classes: Use and Indication is to record whether the patient is taking any medications in specified drug classes and whether the indication was noted for taking each prescribed medication.
Review patient documentation to determine if there is a patient-specific indication noted for all medications in the drug class.
Partner Up to Strengthen OASIS Documentation
It is important to stay regularly updated with CMS’ quarterly Q&As as it helps improve clinicians’ documentation skills and assessment when answering OASIS questions. Completing the OASIS can be challenging due to several considerations and the analysis it requires to get the full picture of a patient’s case.
Therefore, your QA team or provider must be knowledgeable and skilled in dissecting different scenarios and substantiating patient assessments. A good QA can greatly contribute to maintaining optimum reimbursements and harnessing business growth amidst the challenges and opportunities brought by the new OASIS-E and expanded Home Health Value-Based Purchasing Model.