The Centers for Medicare & Medicaid Services (CMS) has released a set batch of quarterly OASIS Q&As. It features inquiries received by their help desk from the second quarter after the introduction of OASIS-E and the conclusion of the COVID-19 Public Health Emergency in May. These Q&As offer valuable insights for navigating complex scenarios in OASIS-E documentation, including the implications of concluding 1135 waivers as the PHE ends. We’ve handpicked a selection of the most useful Q&As from this compilation.
Q&As Worth Noting
OASIS for single-visit quality episodes
Question: We understand that OASIS is not required to be collected when a patient receives only one visit in a quality episode. If a SOC OASIS is completed (to facilitate billing for the single visit), should we also complete a discharge OASIS?
Answer: Based on CMS policy, OASIS data collection and submission is not required when only one visit is made in a single visit quality episode. In some single-visit quality episodes, a SOC OASIS (RFA-1) may be required for billing. Whenever there is a single visit in a quality episode a discharge OASIS (RFA-9) should not be collected or submitted. This refined instruction supersedes previously published guidance in Chapter 3 of the OASIS-E Guidance Manual, eff. January 1st, 2023, and Q46 in Category 2 of the CMS OASIS Q&As last edited 05/22 that simply stated that the discharge OASIS is not required/mandated in the situation of a single visit quality episode.
5-day requirement for the comprehensive assessment waiver at SOC
Question: With the ending of the COVID-19 Public Health Emergency, what is being used to determine when the OASIS assessment completion and transmission waivers have ended? Is it based on the M0090 – Date Assessment Completed or the M0030 – Start of Care Date?
Answer: The temporary guidance waivers were effective through the end of the COVID-19 Public Health Emergency (PHE) declaration. As the end of the PHE was determined to be 11:59 pm May 11, 2023, these waivers expired with that date. For the extension of the five-day completion requirement for the comprehensive assessment waiver at SOC, this would be based on the M0030 – Start of Care (SOC) Date. For example, if the M0030 – SOC Date is on or before 5/11/23, the five-day extension waiver is in effect. However, If the M0030 – SOC Date is on or after 5/12/23, the five-day extension waiver has expired. Regarding the waiving of the 30-day OASIS submission requirement, this would be based on the M0090 – Date Assessment Completed. For example, if an assessment’s M0090 date is on or before 5/11/23, the 30-day submission requirement for that assessment would be waived. If an assessment’s M0090 date is on or after 5/12/23, the 30-day submission requirement is in effect.
C1310 – Signs and Symptoms of Delirium
Question: How should C1310 – Signs and Symptoms of Delirium (from CAM ©) be coded when a patient is comatose at baseline and at the time of assessment?
Answer: If the patient was comatose at baseline and at the time of assessment, code the items as follows:
- C1310A – Acute Onset of Mental Status Changes as Code 0 – No
- C1310B – Inattention as Code 1 – Behavior continuously present, does not fluctuate.
- C1310C – Disorganized Thinking as Code 0 – Behavior not present.
- C1310D – Altered level of consciousness as Code 1 – Behavior continuously present, does not fluctuate.
C1310 – Signs and Symptoms of Delirium (from CAM ©) identifies any signs or symptoms of acute mental status changes as compared to the patient’s baseline status and if there are any signs or symptoms of delirium present at the time of assessment.
Improving OASIS Data Quality
Filling out the OASIS form presents challenges as it involves a comprehensive analysis and understanding of each patient’s unique situation. However, staying updated with the quarterly CMS Q&As can enhance proficiency in addressing assessment items within the OASIS.
To enhance OASIS accuracy, in addition to ongoing clinician education, your QA program should play a substantial role in further reviewing OASIS item responses. By doing so, they can foster patient-centered care, enhance outcomes, and optimize reimbursements particularly as the OASIS data collection for the HHVBP performance year has commenced this year.