2024 ushered in a myriad of changes implemented by the Home Health Final Rule as well as annual updates to the OASIS Guidance Manual. Since so much of our industry’s performance and quality assurance practices rely on data, these updates are important to implement to ensure we are reflecting the care we are delivering accurately. This article will outline updates to the OASIS E Guidance Manual.
Our Updated 2024 OASIS-E 5-Part Training Series provides you with a thorough understanding of OASIS-E guidance and conventions, as well as the intent for each OASIS item. This understanding is foundational to the accurate completion of OASIS-E. To purchase our updated 5-part training series, click here.
Updates to the 2024 OASIS E Guidance Manual include guidance and clarifications in Sections A, C, D, GG, I, J, K, N and O. There were also updated references in Appendix E and minor edits in Appendix F.
Included in the new manual’s Introduction, Chapter 1, is a new section under “Who Completes OASIS?” (1.5.4) regarding OT completion of OASIS. The addition further clarifies changes to OT completion of SOC assessments in cases where SN is NOT ordered on Medicare referrals, but does include PT and/or ST along with OT, and states:
“An OT may conduct and complete the initial assessment and SOC comprehensive assessment when the need for occupational therapy establishes program eligibility. While occupational therapy alone does not establish eligibility for the Medicare home health benefit at the start of care, occupational therapy may establish eligibility under other programs, such as Medicaid.”
While OT has been able to conduct SOC assessments, including OASIS, for Medicare patients when PT and/or ST is ordered (but no SN is included on the referral) since January 1, 2022, there has remained some confusion in the industry regarding the “establishment of eligibility” aspects of this regulation. This section, in its entirety, should help alleviate any outstanding misperception.
In the References and Resources section, Appendix E, it is noteworthy that the section “ICD-10-CM Official Guidelines for Coding and Reporting” no longer has links to the ICD-10-CM Release. This section was replaced by “International Classification of Diseases Official Guidelines” and included a link to the World Health Organization’s ICD-11 Code Set. It is unknown by this author at this time if this means a transition to ICD-11 is in the works; however, traditionally the United States takes the WHO’s code set and clinically modifies it for domestic use. Once we see movement in this modification to ICD-11-CM code set we can anticipate a transition to the updated code set, although no timeline has currently been announced.
A second resource or reference newly included in the 2024 update was a link for National Academies: Health and Medicine Division, while three resources were deleted.
The remaining changes to the 2024 OASIS E Guidance Manual all pertained to Item-Specific Guidance in Chapter 3. This additional guidance is primarily a result of clarifications given at OASIS E Quarterly Q&A publications. Among these changes:
- Clarification that A1110, Preferred Language, “does not report who the interpreter will be”.
- Guidance that “When a patient is discharged after only one visit (a single visit quality episode), a Discharge OASIS should not be collected or submitted.” (Regarding M0100 Reason for Assessment)
- Additional clarification at A2120/A2121 Provision of Current Reconciled Medication List to Subsequent Provider at TF/DC clarifies who is a subsequent provider. At Discharge – A subsequent provider is identified when the patient has been discharged from your agency and remained in a non-inpatient setting receiving skilled services from another Medicare-certified home health agency (M2420 Response 2) or home hospice (M2420 Response 3).
- C1300 Signs and Symptoms of Delirium Item Intent now includes additional verbiage: “The intent of this item is to identify any signs and 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.”
- A new coding tip at C1300A Signs and Symptoms of Delirium, Acute Mental Status Change reads “At discharge, compare the patient’s current mental status to their baseline mental status (prior to the discharge assessment time period under consideration).”
- A note under the item snapshot for D0150 PHQ2 to 9 that instructs the assessor to “Disregard the instruction in the OASIS item that states ‘If either D0150A2 or D0150B2 is coded 2 or 3, CONTINUE asking the questions below. If not, END the PHQ interview.’ This statement is outdated due to refinements in OASIS guidance.”
- A new coding tip to GG0170M, 1 Step; GG0170N, 4 Steps; and GG0170O, 12 Steps; reads “When using a stair lift to ascend/descend stairs, code based on the type and amount of assistance the patient requires to ascend/descend the stairs, beginning once the patient is seated and ending when the patient is ready to transfer out of the seat.”
- New Response Specific Instruction for J0510 – J0530 Pain Interview clarifies that the time period under consideration or “look back period” for the pain interview items “includes the day of assessment in addition to…the last 5 days. The day of assessment for these items is considered day 0”.
- Revised Response Specific Instructions at M1400, When is the Patient Dyspneic or Short of Breath, bullet 2 clarifies the term continuously: “at all times during the day of assessment, with only brief interruptions”.
- Revisions to K0520 Nutritional Approaches now clarifies that the clinician is to determine if any of the listed nutritional approaches “are part of the current care/treatment plan at the time of the SOC/ROC assessment, even if not used at the time of assessment.” Likewise, at Discharge, the clinician is to determine if the listed nutritional approaches were “part of the current care/treatment plan” in the last 7 days and “part of the current care/treatment plan at the time of discharge, even if not used at the time of assessment.”
- A new coding tip was added for K0520B, Nutritional Approaches, Feeding Tube: “If a feeding tube is in place but there are no scheduled or PRN orders to provide nutrition and/or hydration via the feeding tube on the current care/treatment plan, do not code K0520B Feeding Tube.”
- For Section N: Medications, there are multiple revisions. This section now states that the intent of the N items is to “record whether the patient is taking any medications in high-risk drug classes, there is a patient-specific indication noted and the patient/caregiver have been educated about the high-risk medication.”
- Additionally, a new definition for indication is given: “The identified, documented clinical rationale for administering a medication that is based upon a physician’s (or prescriber’s) assessment of the patient’s condition and therapeutic goals.”
- This section now further states that a medication that is part of the patient’s current reconciled drug regimen is to be included, even if it was not taken on the day of assessment.
- We are also instructed, “Do not code flushes provided to keep an IV access port patent as N0415, Anticoagulant”, and to code combination medications in all categories/pharmacologic classes that constitute the combination,” regardless of why the medications are being used.”
- “CMS does not provide an exhaustive list of examples for determining the source for the documented patient-specific indication. Use available resources along with clinical judgment to determine if a scenario meets the criteria for a patient-specific indication.”
- Section O, Special Treatments, Procedures, and Programs also clarifies that the treatments, procedures, or programs the clinician codes should be “part of the current care/treatment plan at the time of the assessment for SOC/ROC or discharge”, “even if not used at the time of assessment, and whether or not it is expected to occur after discharge.”
- O0110H1, IV Medications, clarifies that “IV fluids containing medications” are also coded in addition to those given by IV push, epidural pump, or drip through a central or peripheral port in this item.
- O0110O1, IV Access, now includes clarification that “if there is not a current IV access in place at the time of assessment, do not code IV access for O0110)1, even if a treatment which would require an IV access is part of the patient’s current care/treatment plan” and that IV access for hemodialysis is also included in this item, along with the previously listed long-term medication administration, large volumes of blood or fluid, frequent access for blood sample, IV fluid administration, TPN or in some instances the measurement of central venous pressure.
Since OASIS data items are used in calculation of payment, Quality Reporting, Value Based Purchasing, and/or the certification survey process, agency staff should be aware that publicly published information and payment is impacted by the accuracy of collection of OASIS data. Agencies would be well served to budget resources for OASIS training to ensure assessing staff understand the intent and item guidance for these changes.
HPS Offers Coding and OASIS training that equips home health staff with the education they need to empower your agency to achieve success. Learn more about our Coding Education and OASIS-E Education, today!