The October 2022 OASIS Q&As by the Centers for Medicare & Medicaid Services (CMS) has been released, which address OASIS questions from their help desks. The new set of Q&As shed light on how to deal with specific OASIS items in complex scenarios including new assessment items in the upcoming OASIS-E.
Here are some notable Q&As from the new set:
Question: Please provide an example where the coding for A1250 – Transportation and B1300 – Health Literacy would be different from Start of Care/Resumption of Care to Discharge.
Answer: The intent of A1250 – Transportation is to identify if a lack of transportation has kept the patient from medical appointments, meetings, work, or from getting things needed for daily living over the past 6 to 12 months.The intent of B1300 – Health Literacy is to identify how often the patient needs to have someone help them when they read instructions, pamphlets, or other written material from their doctor or pharmacy. The assessing clinician must consider each patient’s unique circumstances and use clinical judgment to determine how transportation and health literacy applies for each individual patient at both the Start of Care/Resumption of Care and Discharge time points. It is possible that the SOC/ROC and discharge coding are the same.
Question: The rehab therapy definition in the draft OASIS-E Guidance Manual states for J0520: Rehab Therapy – special healthcare service or programs that help a person regain physical, mental, and or cognitive (thinking and learning) abilities that have been lost or impaired as a result of disease, injury or treatment. Can include, for example, PT, OT, SP, and cardiac and pulmonary therapies. Based on the term “regain,” would maintenance therapy not be considered a rehab therapy for the item J0520 – Pain interference with therapy activities?
Answer: Rehabilitation Therapy includes but is not limited to special healthcare services or programs that help a person regain physical, mental, and or cognitive (thinking and learning) abilities that have been lost or impaired as a result of disease, injury, or treatment. Can include, for example, any services provided by PT, OT, SLP, and cardiac and pulmonary therapies.
Question: When coding K0520 – Nutritional Approaches should we only consider those nutritional approaches that the patient actually receives at Start of Care/Resumption of Care (SOC/ROC) and discharge or just those that are included on the plan of care? When coding K0520 at discharge should we only indicate those nutritional approaches that the patient will continue to receive after the patient is discharged?
Answer: K0520 – Nutritional Approaches identifies if any nutritional approaches listed are used by the patient. At SOC/ROC and discharge check all of the nutritional approaches that are part of the patient’s current care/treatment plan during the time period under consideration for SOC/ROC and discharge, even if not used during the time period under consideration for SOC/ROC and discharge. At discharge, K0520 does not report on nutritional approaches that are expected to occur after discharge.
Question: When determining if a medication should be included in one of the 6 high risk drug classes collected in the new OASIS-E item N0415 – High Risk Drug Classes: Use and Indication, which drug classification system should be used? Is there a specific drug classification system that should be used, or can clinicians use any authoritative source even if a system describes the drug classes using terminology that differs from the exact drug classes reported in the item?
Answer: N0415 – High Risk Drug Classes: Use and Indication identifies if the patient is taking any prescribed medication in the specific listed drug classes and whether the patient-specific indication was noted for all medication in the drug class. Code medications according to the medication’s therapeutic category and/or pharmacological classification.CMS does not specify a source for identifying the therapeutic category and/or pharmacological classification.
Question: We have a question regarding O0110 – Special Treatments, Procedures, and Programs. Are special treatments, procedures, and programs that the patient was receiving only during the time period under consideration for Start of Care/Resumption of Care (SOC/ROC) or discharge considered? At discharge, should we also consider what the patient has ordered to receive after discharge (e.g., Chemotherapy or radiation scheduled to begin after discharge)?
Answer: The intent of O0110 – Special Treatments, Procedures, and Programs is to identify any special treatments, procedures, and programs that apply to the patient. Check all treatments, programs, and procedures that are part of the patient’s current care/treatment plan during the time period under consideration for the SOC/ROC assessment and the discharge assessment, even if not received during the SOC/ROC or discharge time period under consideration. Do not consider what is expected to occur after discharge. Include treatments, programs, and procedures performed by others and those the patient performed themself independently or after setup by agency staff or family/caregivers. Check treatments, procedures, and programs that are performed in the care setting, or in other settings (e.g., dialysis performed in a dialysis center).
Leveraging QA for OASIS Accuracy
CMS shares the quarterly OASIS Q&As to help clinicians stay updated and help improve their documentation and assessment skills in answering OASIS questions. Completing the OASIS can be challenging because there are several factors to consider, including the level of analysis needed to be able to get the full picture of a patient’s case.
Leverage your QA team or provider to ensure that accurate documentation of the OASIS and reimbursement potentials are maximized. Make sure they are not only proficient with the OASIS documentation but also updated with the most recent changes in the guidelines, considering the major industry changes underway. These include the new OASIS-E that has adjustments on new assessment items; the HHVBP, which implements payment incentives and penalties alike based on agency performance; and finally, payment cuts as indicated in the FY 2023 final payment rule.