A new set of quarterly OASIS Q&As was released by the Centers for Medicare & Medicaid Services (CMS) to provide guidance on 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. Here are some that are worth taking note of:
Question: Our patient was transported to the hospital and was placed in observation where they expired. Would we complete the RFA 7 – Transferred to an inpatient facility – patient discharged from agency or RFA 8 – Death at home?
Answer: Following updated guidance from October 2021 CMS OASIS Quarterly Q&As Q2, complete an RFA 8 – Death at home OASIS when a patient dies anywhere other than after being admitted for a qualifying inpatient stay. A qualifying inpatient stay is defined as a patient being admitted to an in-patient facility for 24 hours or more for reasons other than diagnostic testing. Only use RFA 7 – Transferred to an inpatient facility – patient discharged from agency when a patient is transferred from your agency for a qualifying inpatient stay and return to your agency is not expected.
Question: I would like further clarification regarding the patient’s ability to take their medications when they do not have them in the home. My patient has unreliable transportation and was unable to get their medications from the pharmacy when needed. The lack of transportation caused the patient to miss three doses of a new oral medication, and one dose of a prescribed injectable that they were unable to refill timely. The new guidance from the January 2022 Quarterly Q&As stated that we assess a patient’s ability based on “patient characteristics, including cognitive status, vision, strength, manual dexterity, and general mobility.” The patient’s lack of consistent transportation is impacting access to their medications. Do we consider this as part of our assessment of M2020 – Management of Oral Medications and M2030 – Management of Injectable Medications?
Answer: M2020 – Management of Oral Medications identifies the patient’s ability to take all oral (p.o.) medications reliably and safely on the day of assessment. M2030 – Management of Injectable Medications identifies the patient’s ability to take all injectable medications reliably and safely on the day of assessment. Note that any assistance or transportation required to get the medication(s) into the home is not considered when coding M2020 and M2030.
Include assessment of the patient’s ability to obtain medications from where they are routinely stored in the home, the ability to read the labels (or otherwise identify the medications correctly, for example, patients unable to read and/or write may place a special mark or character on the label to distinguish between medications), open the containers, select the appropriate dose (pill/tablet, milliliters of liquid, etc.) and orally ingest (or inject) at the correct times.
Once the medication(s) is/are in the home if someone other than the patient must do some part of the task(s) that are required for the patient to access and/or take the medication at the prescribed times, then the assistance required would be considered when determining the code for M2020 and M2030.
Question: A patient is independent with self-feeding but requires encouragement for adequate intake. Would the encouragement to increase food and/or fluid intake be considered when scoring GG0130A – Eating?
Answer: The intent of GG0130A – Eating is to assess the patient’s ability to use suitable utensils to bring food and/or liquid to the mouth and swallow food and/or liquid once the meal is placed before the patient. The adequacy of the patient’s nutrition or hydration is not considered for GG0130A – Eating.
When coding activities in Section GG, clinicians should code based on the type and amount of assistance required allowing the patient to perform the activity as independently as possible, as long as they are safe. If the patient is able to meet the intent of the activity with no assistance (physical, verbal/nonverbal cueing, setup/clean-up) then code 06 – Independent.
Partnering Up to Strengthen OASIS Documentation
Staying regularly updated with CMS’ quarterly Q&As is helpful in improving clinicians’ documentation skills and assessment when answering OASIS questions. Completing the OASIS could be challenging when there are numerous factors to consider, as it demands thorough analysis and understanding of a patient’s case.
Your QA team or provider must be skilled in examining different scenarios and be proactive in finding ways to substantiate patient assessments. This strategic and competent method will ultimately contribute to delivering quality patient care, optimizing reimbursements, and harnessing business growth.