The CMS Quarterly OASIS-E Q&A is a valuable resource for staying current with the latest developments on OASIS-E. During this session, questions from participants covered a wide range of topics, but there are a few key questions that I would like to expand on.
HOW YOU DETERMINE WHETHER TO MOVE ON TO OASIS-E OR CONTINUE WITH OASIS-D
At this point in the game, everything is OASIS-E. The determinant for OASIS-E is the Date the Assessment is Completed (M0090). Even though your patient may have had a Start of Care in 2022, if you are doing a recertification, a discharge, or anything related to that patient’s care, if the date the assessment is completed is in 2023, then you must use OASIS-E.
N0415 – HIGH-RISK DRUG CLASSES: USE AND INDICATION
N0415 – is specific to agencies marking first the class of drugs that the patient is taking and then secondly, whether there is an indication for why they are taking it. The question was asked “can you provide an example of a combination drug that would be in more than one of the listed high-risk drug classes?”
One of the biggest clarifications is twofold. The first part of that is that if the patient is taking a compound drug, that would involve two different classes rather than marking both classes. The Q&A does give you an example that is clear, so be sure to review that in the document (question 10).
The second item is the indication question, and there has been a bit of a cloudy situation regarding exactly what that means. Does it have to be that there is an indication listed on the patient’s care plan? Does it have to be listed on the patient’s medication listing provided by the referring physician? What exactly does it mean and what sources can you get the indication from? In the Q&A, CMS has not given any exact direction. They did provide a list of things that could be used for that indication, but they were clear that there is not an all-inclusive list and to use your judgment.
CMS discussions in the Q&A surround acute care hospital documentation, other staff and clinicians, the patient the patient’s family may supplement or clarify information from the patient’s medical record. So, there is not an all-inclusive list of indications. Be careful in just taking the patient’s word for the indication of a drug because there could be confusion. As you know, there have been plenty of patients that have told Home Health clinicians that they were diabetic and there was no evidence in the medical record that the patient is diabetic. You can get clarification from the patient’s family or caregiver as CMS has stated you can use that to supplement information in the patient’s medical record. It is important to clarify this is to ensure that you understand that it does not simply just have to be on the referral document or specifically listed in a medication list that you have been given directly from a referral source.
If you have any additional questions or need additional clarifications that we can assist with, do not hesitate to let us know.
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