Written by Lisa Selman-Holman, Vice President of Education & Quality, McBee

2023 Ushered in the biggest OASIS-E changes to the data set. The Centers for Medicare and Medicaid Services (CMS) completed OASIS-E implementation at the start of 2023 following a delay caused by the ongoing COVID-19 public health emergency.

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According to CMS, the OASIS instrument was revised to increase standardization across post-acute care settings related to the IMPACT Act passed in 2014. Healthcare organizations need to understand the scope and comprehensiveness of these changes. Not only are there many new and retired items, but the entire structure of the OASIS will change.

Restructuring of OASIS-E Sections In 2023

You will now find sections in the data set representing letters A through Q. Within these sections you will find many new assessment items beginning with those letters, as well as our current OASIS D1 items divided under new sections. 

Many of the existing assessment items remained with the character designation “M” but many were placed in a corresponding lettered section with like items. Section M in OASIS-E represents the integumentary system, so only “M” items that pertain to wounds will be here, other existing “M” items were placed in the letter section they correspond with. For example M1720, “When Anxious,” will be in Section C with other new cognitive items such as the “Brief Interview Mental Screening” (BIMS) and the “Confusion Assessment Method” (CAM).

Additional Assessments Within OASIS-E in 2023

Another area of major change is the new assessments within OASIS-E which include:

  • Brief Interview for Mental Status (BIMS), which establishes a cognitive baseline by testing recall and temporal orientation.
  • Signs and Symptoms of Delirium from the Cognitive Assessment Method (CAM) to help identify delirium which is often reversible if identified early.
  • Patient Mood Interview (PHQ 9), the expanded depression screening, will give further details related to the severity of depression

You should note that the PHQ-2 will still be present in OASIS-E as a gateway assessment. The PHQ-9 would only be completed if the PHQ-2 was positive for depression. A key reminder is that any of these assessment tools are merely screening tools and do not diagnose a condition, which still must come from the provider, but they will help identify issues if present.

Extended OASIS-E Completion Time

Additionally, with these new assessment screenings within OASIS-E comes extra completion time. CMS estimates that once clinicians are familiar with the assessment tools, it will take an additional 2.5 minutes. Under best circumstances for clinicians familiar with the new BIMS, CAM, and PHQ9 assessments, completion of the entire OASIS-E is projected to take an additional 7.5 minutes to complete for just these 3 items.

OASIS-E to OASIS-E1

There are deleted and changed items in addition to one new item confirmed for OASIS-E1, effective with M0090 dates of January 1, 2025, or later.

OASIS-E Removals

The following items will be removed from OASIS as of M0090 date of January 1, 2025, or later:

  • M0110 Episode Timing
  • M2200 Therapy Need
  • Discharge Goal (only) on GG0130 and GG0170

Until these items are removed from OASIS, providers should continue to complete them following the item-specific guidance found in the OASIS-E Guidance Manual – Updated January 1, 2024. (OASIS Quarterly Update—January 2024)

What is the difference and what is the guidance on M0110?

CMS does not use M0110 for anything as of January 2020. It has no use in PDGM. The item will remain in the OASIS for the rest of 2024. The item-specific guidance is to mark it as NA (Not Applicable) if the payor does not use the item. If the payor does use it for PPS-like payment systems, agencies should follow the instructions from the individual payor.

Note that the item and the item-specific guidance indicate a different definition of early and later than we use in PDGM. The first 30-day period of care is an early period of care. The second or later 30-day period of care is a late period of care in PDGM.

Best response: NA

Do we use M2200 for anything?

M2200 was used to determine the number of therapy visits to calculate the HIPPS score under PPS. It also hasn’t been used since 2020 for Medicare PDGM. The item will remain in the OASIS for the rest of 2024, but agencies shouldn’t be struggling with how to answer M2200. NA is the correct answer as it does not apply to Medicare, and Medicare Advantage plans are not using it for determining functional scores either.

Item-specific guidance states that agencies may code M2200 Therapy Need with NA – Not Applicable for assessments where the data is not required for the patient’s payor (including all Medicare FFS assessments).

If a payor requires the number of therapy visits to determine payment, then continue to report the number of therapy visits that are planned for the 60-day certification period.

Best response: NA

What do we need to do with all those discharge goals for GG0130 and GG0170?

GG0130 and GG0170 are not going away but the Discharge Goal column 2 on the SOC/ROC is being deleted as of January 1, 2025. For the rest of 2024 keep this in mind: Setting a Discharge Goal is a process measure. To meet the criteria for the process measure, there must be at least one self-care or mobility discharge goal set. Agencies may save time and choose one discharge goal applicable to the patient and dash the remaining goals; or agencies may continue to choose a discharge goal for every GG0130 and GG0170 item (only certain ones count for the discharge measure) for the rest of 2024. As of January 1, the column will be removed.

Best response: Set a goal for one activity and dash the rest.

Significant OASIS-E Changes to Enrich Patient Outcomes In 2023

The revisions to prior versions of the OASIS as well as the 2023 revisions with OASIS-E are all consistent with the IMPACT Act and interoperability between care settings. By having identical data assessment items as other settings, interoperability will increase when each setting uses the same criteria to complete the data set. For those familiar with the MDS data set, you will notice the similarities to the structure of OASIS-E. Overall, there will be improvements in the safety and quality of care to patients.

OASIS-E is consistent with other initiatives from CMS, with a focus on executing care delivery to patients holistically. The data elements of OASIS-E aid in addressing the needs of individual patients. Organizations are able to collect actionable items such as social determinants of health (SDOH) that lead to better patient outcomes. Identifying SDOH can help organizations be part of the solution in bridging disparities of health care for this patient population.

OASIS-E Transfer of Health Changes

One significant area of change will be the Transfer of Health (TOH) information item. This represents two companion measures that will measure the timeliness of a transfer of a reconciled medication list to a subsequent provider in the next care setting, or to a patient when discharged. Moving forward, TOH will be added to the Home Health Quality Reporting Program. Understanding the connection between TOH items and adverse events will push patient outcomes above competitors throughout the industry. Research shows poor patient outcomes are directly related to medication issues, thus a need to develop a strong process for medication reconciliation and education to mitigate complications.

Excel with McBee’s Best Practices for OASIS-E Changes

OASIS-D1 has a level of comfort and familiarity. Often, we find that clinicians settled in their comfort zone have not kept up with the OASIS guidance changes and clarifications.

Just like any new process, agencies need to provide support through OASIS-E resources and education. This is not a quick feat amid the ever-expanding expectations of the home health clinician. How can your organization achieve this?

Key points to consider when educating your staff on OASIS-E

Stay ahead of the curve: Enroll in OASIS-E training courses and subscribe to McBee Insights to stay up to date on our latest resources and live healthcare training opportunities beyond OASIS-E.

Get real: Encourage staff to share real-life cases to talk through during meetings and as they are happening. Holding a discussion on scenarios or challenges one clinician encounters may assist others in understanding the application of OASIS-E guidance.

Review, Review, Review: Monitor documentation to ensure accuracy and consistency. Quick turnaround of feedback reduces and prevents continued errors and the formation of bad habits.

Collaborate: Whether it is a discussion between nurses or an interdisciplinary team review, the clinician completing OASIS-E should have input from all staff that has contact with the patient during the assessment time frame.

Changes to OASIS-E1

Finally, A Change to M2420

The guidance changed a couple of years ago for formal assistive services options 1 and 2 on M2420. We will have to remember these changes for the rest of 2024.

  • Code 1, Patient remained in the community (without formal assistive services), if, after discharge from your agency the patient remained in a non-inpatient setting, either with no assistive services, or with any assistive services EXCEPT: Skilled services from another Medicare certified home health agency, or Hospice care from a non-institutional (“home”) hospice provider.
  • Code 2, Patient remained in the community (with formal assistive services), if, after discharge from your agency the patient remained in a non-inpatient setting, receiving skilled services from another Medicare certified home health agency, (with or without other assistive services), or when an agency completes a discharge and new SOC OASIS due to a pay source change for a patient.

The item finally gets changed to match the guidance as of January 1, 2025.

D0150 Item Will Be Changed to Match Guidance

Like M2420, the official guidance provided by CMS does not match what the actual item states. Current guidance in the OASIS Guidance Manual states:

Note: 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.

The item will be changed to meet current guidance as of January 1, 2025, by changing the item statement to the following:

Follow new guidance through the end of 2024.

Addition to OASIS-E1

Addition of ‘Patient’s COVID-19 Vaccination is Up to Date’

No action is needed in 2024. Effective with discharges January 1, 2025, agencies will need to determine the patient’s vaccine status. “Up to date” will be determined by the CDC, but as of now, there is no guidance.

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