Provider Questions

Provider Questions:

Questions from the April 2024 CMS Quarterly OASIS Q&As 

1) A third-party external auditor consistently states that our OASIS functional status items are “underscored” and recommends changing the responses to the OASIS items. Is the assessing clinician required to accept the auditor’s recommendations? 

2) Question 2: How are the Symptom Control Ratings defined for Column 2 for M1021/M1023 - Primary Diagnosis/Other Diagnoses?  It seems that the definitions that used to be in the item have been removed. 

3)  For M1830 - Bathing, Code 2 - Able to bathe in shower or tub with the intermittent assistance of another person, includes three examples. Since the item says “OR” after each example, and not “AND/OR” does this mean that if the patient requires assistance with more than one of the examples, we should select Code 3 - Able to participate in bathing self in shower or tub, but requires presence of another person throughout the bath for assistance or supervision instead of Code 2?

4) We have a patient that lives alone and receives assistance for bathing and dressing once per week but safely completes the activities alone on the other days, when assistance is not available. When coding GG0100A - Prior Level of Functioning: Everyday Activities; Self-Care, would this scenario indicate Code 2 - Needed some help, or would Code 3 - Independent be indicated? 

5)  For OASIS coding, if a patient has a seizure which causes them to fall and sustain a subdural hematoma, is this considered a fall with major injury? 

6) When we complete a drug regimen review, our EMR software runs an interaction check between all the patient’s medications and flags any pertinent potential interactions. Our agency policy is to notify the physician within 3 days if any “high or medium alerts” are triggered.  We want to confirm that our agency policy regarding this can be interpreted differently than the criteria used to identify a potential (or actual) clinically significant medication issue for M2001 - Drug Regimen Review. For example, we can comply with our agency policy to notify a physician when a high medication interaction is triggered by our EMR software, and still not consider it a potential (or actual) clinically significant medication issue, if the assessing clinician does not feel the situation warrants communication with the physician by midnight of the next calendar day. Our specific question is, is there anything related to our approach as described that does not align with the instructions for coding of M2001 - Drug Regimen Review?