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Answers to Provider Questions:

1) Discharge should be made at the end of the 60-day certification period in all cases if the beneficiary has not returned to the HHA. If the beneficiary returns to HH after an inpatient stay that spans the end of the certification period, Medicare requires a new SOC assessment.  The HHA is not required to update the agency discharge, as this date should have been captured when the patient transferred to the inpatient facility. 

2) Per an answer provided by CMS HHA Survey Protocols (hhasurveyprotocols@cms.hhs.gov), "Based on the scenario they were correct not to add a pending insurance to the OASIS – therefore this runs into the 30-day submission requirements per the CoPs and there isn’t a way to get around it." 

3) CMS OASIS Q&As: CATEGORY 2 - COMPREHENSIVE ASSESSMENT

Q38. I assume that a patient who is no longer receiving skilled care but continuing to receive personal care only will cease OASIS data collection at the end of skilled care. Is this correct? If it is, how should OASIS items M0100 - Reason for Assessment and 

M2420 - Discharge Disposition be answered in the discharge assessment?

[Q&A EDITED 05/22; EDITED 10/16]

A38. We encourage HHAs to complete a discharge OASIS assessment for a patient who no longer requires skilled care but continues to receive personal care only. While this is not a requirement, conducting a discharge OASIS assessment at the point where the patient's skilled need has ended provides a clear endpoint to the patient's quality episode for purposes of the agency's quality initiatives. In this case, OASIS item M0100 - Reason for Assessment should be marked with Response 9 (Discharge from agency). While the patient may continue to receive personal care services from a Medicare-certified home health agency, since the

services are not skilled, OASIS item M2420 - Discharge Disposition should be marked with Response 1 - Patient remained in the community (without formal assistive services). 

Per the guidance manual, OASIS data are collected for skilled Medicare and Medicaid patients, 18 years and older, except for patients receiving services for pre- or postnatal conditions. Those receiving only personal care, homemaker, or chore services are excluded from OASIS data collection and submission requirements.

For OASIS purposes, a quality episode must have a beginning (a SOC or ROC assessment) and a conclusion (a Transfer, Death at Home, and Discharge assessment) to be considered a complete quality episode.

It sounds like to me that the change/upgrade in the HHA's software put things more in line with CMS guidelines. Maybe the HHA was acting outside the guidelines and maybe even the CoP. If the patient no longer requires 'skilled' services, they should be discharged, to properly close the episode. If the patient required skilled services and returned to the HHA and it was still in the window of the episode, a ROC would be completed. If the patient returned to the HHA after the time frame for the episode had lapsed, then a SOC would be completed to start a new episode. 

Answers to the January 2024 CMS Quarterly OASIS Q&As:

1)  CMS plans to remove M0110 - Episode Timing and M2200 - Therapy Need and the GG Discharge Goals from the OASIS instrument effective January 1, 2025. At this time the new COVID item will be added. Data collection using the OASIS-E1 version of the instrument will begin with OASIS assessments with an M0090 date on or after January 1, 2025. 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. 

2) If there is a current IV access in place at the time of assessment that is used for dialysis or during dialysis for another purpose, for example, a central venous catheter, then check O0110O1 - Special Treatments, Procedures, and Programs; IV Access. An AV fistula, whether it is being accessed or not, does not meet the definition of IV Access for O0110O1.