Answers:
1) The clinician who performs the home care visit collects the OASIS data. This person can be an RN, Physical Therapist, Occupational Therapist, or Speech-Language Pathologist, any of whom can complete any type of OASIS assessment.
2) Answer provided by CMS in OASIS Q&A May 2022:
When an agency does not complete a recertification assessment within the required 5-day window at the end of the certification period, the agency should not discharge and readmit the patient. Rather, the agency should send a clinician to perform the recertification assessment as soon as the oversight is identified. The date the assessment was completed (M0090) should be reported as the actual date the assessment was completed, with documentation in the clinical record of the circumstances surrounding the late completion. A warning message will result from the non-compliant assessment date, but this will not prevent assessment transmission. No timeframe has been set after which it would be too late to complete this late assessment, but the agency is encouraged to make a correction or complete a missed assessment as soon as possible after the oversight is identified. This situation should be avoided, as it does demonstrate non-compliance with the comprehensive assessment update standard (of the Conditions of Participation). For the Medicare PPS (PDGM) patient, payment implications may arise from this missed assessment. Any payment implications must be discussed with the agency's Medicare Administrative Coordinator (MAC).
3) Reply received from The CMS Home Health Quality Help Desk:
In the case of an unplanned (end-of-home care where no in-home visit can be made), the last qualified clinician who saw the patient may complete the discharge comprehensive assessment document based on information from their last visit. The assessing clinician may supplement the OASIS items on the discharge assessment with information documented from patient visits by other agency staff that occurred in the last 5 days that the patient received visits from the agency prior to the unplanned discharge. The “last 5 days that the patient received visits” are defined as the date of the last patient visit, plus the four preceding calendar days.
In the case of an unplanned discharge, utilize the following guidance to complete the OASIS:
Items where a dash is a valid response: When there is no information available because the assessment of the item was not completed prior to the unplanned discharge, a dash may be the only valid response. A dash indicates “no information available” and CMS expects dash use to be a rare occurrence.
Patient Interview items where a dash is a valid response (BIMS & PHQ-2 to 9): When assessing C0200- C0500 - Brief Interview for Mental Status (BIMS) and/or D0150 - Patient Mood Interview (PHQ-2 to 9), a patient interview is required to complete these items. If a clinician is not able to complete the assessment of these items due to an unplanned discharge and there is no documentation that the interview was completed in the last 5 days that the patient received visits, then a “dash” is the only allowable response.
Items where a dash is NOT a valid response: If an assessment of an item was not completed prior to the unplanned discharge and there is no information available from the last 5 days the patient received visits, code the item using any available documentation/information. For patient interview items, where the dash is not a valid response, if the patient is unable to respond due to an unplanned discharge and it is allowable, code X or code 8 - Patient unable to respond, depending on the item. Review the guidance manual and Q&As for item-specific guidance.
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