For home health agencies, the holidays mean more than spending time with family and time off work. Change is a constant of the home health industry, and the introduction of OASIS-D1 on January 1, 2020 proves this to be true. Luckily, the revisions occurring under OASIS-D1 are considered minor – but as we know, even the tiniest of changes require a good bit of thought as to how you’ll handle the revisions throughout your own agency.

The minor revisions in OASIS-D1 include the addition of two existing items to the Follow-Up assessment data set: M1033 Risk for Hospitalization and M1800 Grooming. Both items will be used under PDGM to identify the Functional Impairment Level for the patient. Guidance revisions include a change from required data collection to optional data collection at certain time points for 23 OASIS items. Additionally, CMS is allowing a one-time exception for any RFA 4 Recertification Assessments completed in the last five days of 2019. There is no revised version of the OASIS-D Guidance Manual for 2020.

M1033 Risk for Hospitalization

OASIS item M1033 Risk for Hospitalization identifies patient characteristics that may indicate the patient is at risk for hospitalization. The clinician should mark all that apply and must understand the time period under consideration for each item. The time periods for each item varies from the day of assessment to the past 12 months.  Multiple OASIS Q&As were released in October 2019 with clarification of M1033 Risk for Hospitalization coding. The types of hospitals included in code 3 include only acute care hospitalizations. Inpatient psychiatric and long-term care hospitals (LTCHs) are not included. The criteria for an inpatient hospitalization have not changed, so the patient must be admitted for 24 hours or longer to an inpatient acute bed for more than just diagnostic testing.  Observation stays are not included. For code 4 – Multiple Emergency Department Visits, the patient must be seen in a hospital emergency department. This item does not include urgent care centers, walk-in clinics or emergent MD office visits as defined in M2301 Emergent care.  Code 7 – Currently Taking 5 or More Medications includes all prescribed and over the counter (OTC) medications regardless of the route of administration.  Total Parenteral Nutrition (TPN) and oxygen as defined in M2001 Drug Regiment Review are also included.  A decline in mental, emotional or behavioral status is considered a change in which the patient, family, caregiver or physician has notes as a decline regardless of the cause. The decline may be temporary or permanent.

M1800 Grooming

OASIS item M1800 Grooming identifies the patient’s ability to tend to personal hygiene needs excluding bathing, shampooing hair and toileting hygiene.  The assessing clinician may consider available input from other agency staff who have had direct patient contact.  Patient access must be considered when determining grooming ability (e.g., grooming aids, mirror, sink). If there is an environmental barrier preventing safe access or the patient has an impairment that causes him/her to require someone’s assistance to gain access to needed items or locations, whether the assistance was to take the items to the patient, or to assist the patient to get to the items, Response “1 – Grooming utensils must be placed within reach before able to complete grooming activities” would be appropriate, assuming the patient could then groom independently in a majority of the more frequently performed grooming tasks.

Optional Data Collection

Data collection at certain time points for the 23 existing OASIS items is optional.  Agencies may enter an equal sign (=) for these items, at the specified time points only. This is a new valid response for these items at these time points; the items themselves are unchanged. The equal sign (=) indicates that the agency has chosen not to report on this OASIS item.  Agency policy and procedures should address when clinicians are allowed to use the equal sign for these items.

The 23 items and time points are listed as follows:

RFA #1 Start of Care/ RFA #3 Resumption of Care (SOC/ROC)

  • M1910 Fall risk Assessment

RFA #6 & 7Transfer (TRN) and RFA #9Discharge (DC)

  • M2401a Intervention Synopsis: Diabetic Foot Care
  • M1051 Pneumococcal Vaccine
  • M1056 Reason Pneumococcal Vaccine not received

RFA #4 Follow-Up (FU)

  • M1021 Primary Diagnosis
  • M1023 Other Diagnoses
  • M1030 Therapies
  • M1200 Vision
  • M1242 Frequency of Pain Interfering with Activity
  • M1311 Current Number of Unhealed Pressure Ulcers at Each Stage
  • M1322 Current Number of Stage 1 Pressure Injuries
  • M1324 Stage of Most Problematic Unhealed Pressure Ulcer that is Stageable
  • M1330 Does this patient have a Stasis Ulcer
  • M1332 Current Number of Stasis Ulcers that are Observable
  • M1334 Status of Most Problematic Stasis Ulcer that is Observable
  • M1340 Does this patient have a Surgical Wound
  • M1342 Status of the Most Problematic Surgical Wound that is Observable
  • M1400 Short of Breath
  • M1610 Urinary Incontinence or Urinary Catheter Presence
  • M1620 Bowel Incontinence Frequency
  • M1630 Ostomy for Bowel Elimination
  • M2030 Management of Injectable Medications
  • M2200 Therapy Need

RFA 4 – Recertification Assessments

Effective date for the changes to the OASIS data set and data collection guidance are effective with a M0090 Date of Assessment Completed on or after January 1, 2020.  To support the transition to the Patient-Driven Groupings Model (PDGM), the changes also apply to RFA 4 Recertification assessments with an M0090 Date Assessment Completed date on or after December 27, 2019, where that assessment must provide the Health Insurance Prospective Payment System (HIPPS) code for a PDGM payment episode that begins January 1, 2020 or later. CMS has issued a special wavier to accommodate this transition, which works as a one-time exception to facilitate the transition to the Patient-Driven Groupings Model (PDGM).

CMS has instructed agencies to report an artificial date of 1/1/2020 in M0090 Date of Assessment Completed for RFA 4 – Recertification assessment completed in the last five days of 2019 (12/27/2019 – 12/31/2019) for the Episode from date of 1/1/2020 through 1/5/2020. Please note the RFA 4 – Recertification OASIS should not be submitted until 1/1/2020 or after or the agency will receive a fatal error preventing the transmission of the assessment. See below for an example of a Transition Recertification Example:

CMS Transition Recertification Example:

  • SOC date November 3, 2019
  • Recertification assessment (using OASIS-D1 Follow-up instrument) is completed on December 29, 2019 (for the subsequent episode of continuous care beginning January 2, 2020)
  • Report artificial M0090 date of 1/1/2020
  • Submit this assessment no earlier than 1/1/2020.

More OASIS & Coding insights:

CMS Memo – OASIS-D1: OASIS Update for CY 2020

Webinar: OASIS in a PDGM World — The Clinical Perspective

Webinar: Diagnosis Coding in a PDGM World — The Clinical Perspective

Have questions about how OASIS-D1 will affect your agency? Contact us to learn more about our OASIS & Coding education and solutions to prepare for the OASIS updates.