The Centers for Medicare & Medicaid Services (CMS) has announced the transition from OASIS-C to OASIS-C1/ICD-9 beginning January 1, 2015. We’ll have a more in-depth article about that soon but for right now, it feels like a good opportunity to talk about OASIS Assessments in more general terms. For starters, the two best resources for OASIS answers are the CMS website (look for Guidance Manuals at the bottom of the page) and the OASIS-C Best Practice Manual from Fazzi Associates.
First, let’s talk about the overall rules that apply to each OASIS assessment. The most important thing you need to know is that one person completes the OASIS assessment and takes responsibility for the content of the information specified. Clinicians can discuss the client’s condition as a multi-disciplinary team but the person who signs the OASIS is attesting that the information is true and correct. Equally important to remember is that a Physical Therapist Assistant (PTA), Occupational Therapist Assistant (OTA), Home Health Aide / CNA (HHA) or Medical Social Worker (MSW) may not complete any OASIS assessments and OTs may not complete the Start of Care (SOC) assessment. Also, all OASIS assessments must be transmitted to the state within 30 days of the Start of Care or the date in Date Assessment Completed.
The first OASIS assessment to be documented is the Start of Care (SOC) assessment. This assessment is used when a patient is admitted for treatment to a home health agency. When nursing is ordered, either on its own or as part of a multi-discipline referral, the RN must complete the SOC assessment. If therapy is ordered without nursing, a PT or SLP may complete the SOC assessment. The SOC assessment has to be finished within 5 calendar days of the Start of Care date (the date of the first billable visit in the episode). The SOC assessment must be based off of the information collected during an actual visit with the patient. M0030 (Start of Care Date) will be the date of the first billable visit and M0090 (Date Assessment Completed) will be the date the assessment is completed by clinician. This means that if the original clinician finds information that changes some OASIS responses within 5 days of the SOC date, the M0090 date becomes the date of the updated clinical findings while M0030 remains the actual SOC date.
We’ve now successfully admitted our patient for services. Suppose the patient is later transferred to an inpatient facility (more than likely a hospital). If the inpatient admission has been less than 24 hours or was an observation period without admission, the Transfer OASIS assessment is not required. If a patient has been admitted to a facility for over 24 hours and you anticipate the patient returning to home care within their current episode, a Transferred to an inpatient facility – patient not discharged from agency assessment would be completed. If it is reasonable to assume that the patient will not return to home care before their episode has ended, a Transferred to an inpatient facility – patient discharged from agency assessment is more appropriate. Either of these assessments can be completed by an RN, PT, OT, or SLP and must be done so within 2 calendar days of the discharge/transfer date (M0906). The Transfer OASIS assessment may be completed without an actual visit to the patient.
Our patient has returned following their inpatient stay and now a Resumption of Care (ROC) OASIS has to be charted. The ROC OASIS may be completed by an RN, PT, OT, or SLP. It must be done based off of an actual home visit and must be finished within 2 calendar days of the facility discharge date or when the agency has been alerted the patient is home. M0032 is set to the date the Resumption of Care is completed.
Now you’re approaching the end of the episode and have a decision to make – does the patient require continued care? If yes, you will document a Recert OASIS during the last five days of the ending episode. This means that if an episode ends on September 26th, for instance, you must schedule a visit for the 26th, 25th, 24th, 23rd, or 22nd to complete the Recert OASIS. This assessment must be based off of a visit with the patient and may be documented by an RN, PT, OT or SLP. Remember, OTs may not stand alone at the start of care but Medicare regulations allow an OT to be in without any other qualifying services for one recertification episode if it is clinically necessary.
An Other Follow Up assessment may be completed if the clinical condition of the patient has notably improved or declined, outside of the anticipated disease process, in the middle of the episode and you wish to report this Significant Change in Condition (SCIC) to Medicare. This type of assessment may be completed by an RN, PT, OT or SLP and can be accompanied by an update in the care plan.
Now we come to the time where the patient requires a discharge from services. There are several reasons for discharge. The first, and most favorable, is a discharge due to goals met. In this case, a Discharge from agency not to inpatient facility is completed based off of the last billable skilled visit. It must be performed by the RN, PT, OT or SLP. The Date assessment completed (M0090), Date of Last (Most Recent) Home Visit (M0903) and the Discharge Date (M0906) will be the date of the last visit. Of course, life is not always as neat as that and sometimes unanticipated events will end up being the cause for patient’s discharge.
If the discharge is unanticipated but is not a transfer to inpatient facility, a Discharge from agency not to inpatient facility is still going to be assessment to perform. Examples of this are a patient refusing further services, moving out of the service area, or an MD canceling home health services. In this case, M0090 would be the date the OASIS is completed after learning of the need to discharge, M0903 would be the date of the last billable visit (even if completed by a PTA, OTA, MSW, LPN, or HHA) which could be the discharge visit itself if it happens to be a billable visit, and M0906 would be the date assessment is completed unless the home health agency has a policy where the discharge date is the date of the last billable visit. The skilled discipline who completes the Discharge OASIS should note “based on the visit dated mm/dd/yyyy” in case the discharge was done without a visit. Remember, this assessment still must be completed by an RN, PT, OT or SLP and should be answered to the best of their ability.
If a patient is discharged due to their passing away in their home, a Death at home assessment should be documented within 2 calendar days of the death or the agency’s notification of the death. This assessment should be completed for any death that does not occur in an emergency room or inpatient facility. The Discharged from agency assessment is not required in this case. Though a death at home is considered a sentinel event and ought to be reported to the home health agency’s quality improvement, performance improvement, or clinical management staff as soon as you become aware.
That does it for this general discussion of OASIS assessments. If you have any questions or need additional help, you should contact the home health agency’s clinical management personnel for guidance or check out the online resources from CMS and Fazzi Associates noted at the beginning of this article.