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

OASIS-E to OASIS-E1

There are deleted items, changed items and 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.

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.

WATCH NOW

Webinar | OASIS-E Quarterly Update: January 2024

Listen in as our McBee experts review the latest OASIS-E updates provided by the Centers for Medicare & Medicaid Services (CMS) including the draft release of OASIS-E1 and apply the new guidance to scenarios.

WATCH NOW
Lisa Selman-Holman, JD, BSN, RN, HCS-D, COS-C Vice President, Education & Quality

About the Author

Lisa Selman-Holman, JD, BSN, RN, HCS-D, COS-C, VP of Education & Quality

Lisa Selman-Holman, JD, BSN, RN, HCS-D, COS-C, is the VP of Education & Quality at McBee, bringing over 35 years of expertise in home health and hospice. As a registered nurse and home care attorney, she specializes in regulatory compliance. Lisa has held various roles, from field nurse to executive, managing accreditation surveys, acquisitions, and regulatory crises. In 2004, she founded Selman-Holman & Associates, offering consulting, coding and OASIS review services. Lisa is a renowned educator, known for turning challenges into achievements. Joining McBee in 2021, she leads education initiatives at the Post-Acute Academy, providing courses for home health and hospice staff and executives, including clinical, regulatory and onboarding requirements.

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