With the next version of the Outcome and Assessment Information Set (OASIS) -- OASIS-C -- about to go into effect Jan. 1, 2010, the National Association for Home Care & Hospice (NAHC) has been submitting questions about OASIS-C to the Centers for Medicare & Medicaid Services (CMS) OASIS Mailbox Team. In addition, other organizations and consulting groups share the CMS OASIS Mailbox Team Q&As that they have received. These Q&As are printed in NAHC Report and posted on the NAHC website as they are received. Below are the OASIS-C answers received to date from CMS.

FALLS RISK ASSESSMENT

1. Does the falls risk assessment on the MedQIC website meet CMS criteria for "multi-factor" and "validated?"

CMS Response: The multi-factor falls risk assessment must include at least one standardized tool that (1) has been scientifically tested on a population of community dwelling elders and shown to be effective in identifying people at risk for falls and (2) includes a standard response scale. It is the agency's responsibility to determine if the tools it is considering for the OASIS-C M item best practice assessments meet the requirements as detailed in Chapter 3 of the OASIS-C Guidance Manual and the CMS OASIS OCCB Q&As.

Note: The MedQIC tool referenced in Question #1 is the Missouri Alliance for Home Care's screening tool. Based on CMS' response, it does not meet validation requirements at this time. However, the Missouri Alliance is seeking validation of its tool, and NAHC will advise agencies once the process has been completed.

2. Does this risk assessment screening tool in the resources section of the OASIS C Guidance Manual meet the criteria of a standardized and validated tool? "Home Care Fall Reduction Initiative risk  Assessment Screening Tool (A multi-factor falls risk screening tool from the Missouri Alliance for Home Care, specifically designed for home care patients at Start of Care and Re-certification)" (Submitted by Fazzi Associates)

CMS Response:  The Missouri Alliance for Home Care (MAHC) tool, at this time, has not undergone the process of validation. The MAHC tool can be used in conjunction with a standardized, validated performance assessment like the TUG (Timed Up and Go) or Functional Reach Assessment to meet the requirements of the multi-factorial standardized validated falls risk assessment. 

TOILETING HYGEINE

3. What if a patient has a new colostomy and is completely dependent on someone to empty the appliance (bag) as well as change the appliance but she can cleanse herself and care for her clothing with voiding? The patient usually changes the bag one to two times per week -- unless there are problems. Is this patient a "0"? Are we interpreting correctly that the only way we would ever score this patient a "3" is if she is changing the appliance more often than she is voiding?   

CMS Response: M1845-"Toileting Hygiene" assesses the patient's ability on the day of the assessment to manage personal hygiene and clothing when toileting. If the patient has a colostomy, the hygiene would include cleaning (wiping) the perineal area after voiding and around the stoma when necessary. M1845 does not include the patient's ability to manage the ostomy bag, stoma wafers, or other ostomy equipment. On the day of the assessment, if the patient has the ability to safely manage his or her clothing and perform the personal hygiene as described above, the appropriate score would be a "0". How often the appliance (equipment) is changed does not factor into the scoring of this item.

OASIS-C FORMATTING

4. Is it permissible to add "hints" to our home-made OASIS C forms from the Chapter 3 OASIS item guidance to ensure continuity among our clinicians? In addition, is it permissible to indicate next to the "M" questions if they are a process item, non-routine supply item, Home Health Compare item, and outcome measure items?  

CMS Response: Each agency may develop its own comprehensive assessments as it sees fit (including the addition of "hints" and other notations) as long as the assessment includes items that assess the patient's continuing need for home care services and determine the patient's medical, nursing, rehabilitative, social, and discharge planning needs; eligibility for the payer's benefit; and the required OASIS items for patients that require OASIS data collection. The OASIS items must be incorporated into the assessment exactly as written, although skip patterns may be modified as needed if the agency chooses to change the sequence of the items. Refer to other CMS OASIS Q&As under Category 4a for further guidance related to formatting of the items into software. 

PHYSICIAN DESIGNEE

5. Could a pharmacist be a physician designee for M2002-"Medicare Follow-up"?

CMS Response: A pharmacist is not typically a "physician- designee" in OASIS reporting. A physician designee is an individual who works in cooperation with and has been authorized by the physician (within his or her scope of practice) to facilitate care and communicate the physician's orders. When completing the OASIS Medication process measure items, the pharmacist is only considered a "physician-designee" in a very limited situation. If, within one calendar day of identifying a clinically significant medication issue, the agency clinician communicates with the physician regarding the issue, the physician calls in a prescription change to the pharmacy causing the pharmacist to issue a prescription, then technically the pharmacist could convey the information. In this case, the clinician would still need to get an order from the physician

HIGH-RISK DRUG EDUCATION

6. For the assessing clinician to select a "Yes" response to M2010, must the high-risk drug education be provided on the actual start of care/resumption of care visit or can it be provided/completed on another visit by the same clinician within five days of start of care and two days of resumption of care? (Submitted by Fazzi Associates)

CMS Response: To respond "1-Yes" for M2010-"Patient/Caregiver High-Risk Drug Education," the patient and/or caregiver must receive the specified education for all high-risk medications within the assessment timeframe. It is not required that it all occur on the actual start of care/resumption of care visit. 

The education can be provided by clinicians other than the clinician responsible for completing the assessment. Please see the M2010 response-specific instructions in Chapter 3, which references how to handle situations where other agency staff is providing the education.

ASSESSMENT COMPLETION DATE

7. Does "assessment completed date" refer to information required to complete OASIS data items or any information contained within the agency's comprehensive assessment? (Submitted by Fazzi Associates)

CMS Response: M0090- "Date Assessment Completed" is referring to the date the entire assessment was completed. The OASIS is just one component of the comprehensive assessment.