2015 is shaping up to be a big year for home health regulatory changes. The latest change is in the OASIS data set. CMS has been gearing up for the ICD-10 conversion for some time now and had updated the OASIS document to allow for ICD-10 codes and took the opportunity to clarify some of the other OASIS questions. ICD-10 was supposed to go into effect in October, 2014 but a provision of the Protecting Access to Medicare Act of 2014 delayed implementation until October 1, 2015. As a result, CMS created the OASIS C1/ICD-9 version which is to be used for any OASIS with the M0090 Date Assessment Completed date on or after January 1, 2015 up until the ICD-10 codes become effective.

Most of the changes within this new version are verbiage, font and minor punctuation changes aimed at clarifying the intent of certain questions. “e.g.”s and “i.e.”s throughout the OASIS have been changed to “for example” or “specifically”. Other changes include:

  • M1000 – “during the past 14 days” has been changed to “within the past 14 days” and
  • M1500, M1510, M2004, M2015, M2300, M2400 – “At any point since” and “since” has been changed to “at the time of or at any time since”.

Some other changes expanded upon examples or added verbiage to clarify situations where the response would be appropriate for the patient.

  • M1100 – added “residential care home” as an example of a congregate situation,
  • M1240, M1730, and M1910 – require that assessments not only be “standardized” but “validated” as well,
  • M1510 – added “telehealth” as an example of a change in care plan orders,
  • M1900 – added “toileting hygiene” as an example of self-care and “phone use” as an example of household tasks,
  • M2000 – adds “adverse” to the term “drug reactions”,
  • M2004 – allows for contact to the physician within one day of any “identified” clinical issues regarding medication,
  • M2102 – specifies “Non-agency” caregivers and adds “home exercise program” as an example of a medical procedure/treatment,
  • M2310, M2430 – adds “adverse drug reactions” to the first response

Some questions were deleted either because they were deemed irrelevant or the changes required the addition of a new question.

  • M1012 – deleted as irrelevant
  • M1032 – deleted and replaced with M1033 which has more options to choose from,
  • M1040 – deleted and replaced with M1041 which simply asks whether the episode occurred during a valid period,
  • M1045 – deleted and replaced with M1046 which collects data about whether the patient received the immunization,
  • M1050 – deleted and replaced with M1051 which asks if the patient received the pneumonia vaccination,
  • M1055 – deleted and replaced with M1056 which collects data about why the patient has not received the pneumonia vaccine,
  • M1310, M1312, M1315 – deleted
  • M2100 – deleted and replaced with M2102 which combines the columns that pertain to the likelihood or whether it is clear that caregivers will provide assistance.

The wound care section (M1300 through M1350) has been updated with some questions adding language to clarity the intent of the questions and responses. The grid for M1308 has been reformatted to allow for only the number of currently present pressure ulcers and a grid for M1309 has been added to report the status of worsening pressure ulcers.

Also the grids for the Plan of Care Synopsis (M2250) and Intervention Synopsis (M2400) have been expanded upon to provide more instruction about each intervention and clarify when the Not Applicable (NA) response is appropriate.

The final draft of the OASIS C1/ICD-9 can be found here.

It is essential that all home health personnel who complete OASIS forms have the new OASIS C1/ICD-9 version available to them effective January 1, 2015. Home health agencies can follow up with software vendors and paperwork vendors to ensure that they receive the items as soon as possible. therapyBOSS will have the OASIS C1/ICD-9 version automatically chosen for any visits on or after January 1, 2015 for the convenience of our users.