On August 31, 2017 CMS issued a statement and an update to the OASIS-C2 Guidance Manual regarding the One Clinician Convention. CMS states: “As required by the Conditions of Participation, the Comprehensive Assessment will continue to be the responsibility of one clinician. However, effective January 1, 2018, the assessing clinician will be allowed to elicit feedback from other agency staff, in order to complete any or all OASIS items integrated within the Comprehensive Assessment.”

One key element that agencies should ensure that is understood is the caveat “For OASIS items requiring a patient assessment, the collaborating healthcare providers (e.g., other agency clinical staff: LPN/LVN, PTA, COTA, MSW, HHA) should have had direct in-person contact with the patient, or have had some other means of gathering information to contribute to the OASIS data collection (health care monitoring devices, video streaming, review of photograph, phone call, etc.).”

Agencies should also note that the M0090 date “The Date the Assessment is Completed” should be reflective of the date that the assessing clinician gathered or received any input used to complete the comprehensive assessment document, which includes the OASIS. Note that this date should not be reflective of the date that a quality review team member or coder final reviewed the document. It is the date that the last piece of assessment documentation was gathered.

A very helpful clarification is also included in this document regarding discharge assessments: “In the case of an unplanned or unexpected discharge (an end of home care where no in-home visit can be made), the last qualified clinician who saw the patient may complete the discharge comprehensive assessment document based on information from his/her last visit. The assessing clinician may supplement the discharge assessment with information documented from patient visits by other agency staff that occurred in the last 5 days that the patient received visits from the agency prior to the unexpected discharge. The “last 5 days that the patient received visits” are defined as the date of the last patient visit, plus the four preceding days.” There is NO allowance for a “phone discharge” NOR has there ever been.

In addition to the above clarifications, it should also be noted that there will be some pretty significant changes come to the OASIS data set beginning in 2019. The current Proposed 2018 Home Health Rule includes proposed updates to the Home Health Quality Reporting Program (HH QRP) that would begin in 2019 and in addition to tweaking specific assessment items to more closely align with other Post-Acute Care Provider Assessments, there is a proposal to eliminate 35 OASIS data set items. The list of items to be removed do not currently impact reimbursement, survey, calculation or quality measures, Value Based Purchasing or care planning.

The list is below:

CMS is requesting comments on all the proposed changes. The comment period closes on 9/25/17.

Check out our Home Health Pocket Guide to OASIS C2! This detailed guide is a valuable tool for your clinical field staff. It features an item-by-item breakdown of OASIS-C2 documentation and information on the reimbursement impact.