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Test Your Knowledge Answers:

1) Per CMS Home Health Quality Questions:

In response to your question “Which assessments need to be completed?”

The RFA 5 - Other Follow-up is the comprehensive assessment including OASIS that is conducted due to a major decline or improvement in patient's health status occurring at a time other than during the last five days of the episode (days 56-60 when the RFA 3 is required). This assessment is done to re-evaluate the patient's condition, allowing revision to the patient's care plan as appropriate. Each agency must determine its own policies regarding examples of major decline or improvement in health status and ensure that the clinical staff is adhering to these policies.

In this scenario, even if the patient experienced a major decline or improvement in patient's health status that met your agency’s policy for completing an RFA 5, if it occurred during the last five days of the episode (days 56-60) the RFA 3 – Recertification would be completed instead of the RFA 5.

Thank you for your commitment to home health quality.

The CMS Home Health Quality Help Desk Team - January 2022"

2) Per the OASIS Guidance Manual:

Chapter 3: Section A - Patient Tracking "If the patient is a member of a Medicare HMO, another Medicare Advantage plan, or Medicare Part C, enter the Medicare number if available. If not available, mark “NA – No Medicare.” Do not enter the HMO identification number."

"Mark all current pay sources, whether considered primary or secondary. Select Response 2 if the payment source is a Medicare HMO, another Medicare Advantage Plan, or Medicare Part C."

Chapter 3: Section B - Clinical Records Items "The date authorization was received from the patient’s payer is NOT the date of the referral (for example, the date the Medicare Advantage case manager authorized service is not considered a referral date)."

Appendix F: "The OASIS-based quality measures are calculated using items from the OASIS assessments from Medicare FFS, Medicare Advantage, Medicaid and Medicaid Managed care."

3) In Question #5 of the July 2020 CMS OASIS Quarterly Q&As, CMS provided temporary guidance effective through the end of the public health emergency. CMS waived the requirements in 42 CFR § 484.55(a)(2) and § 484.55(b)(3) which stated that rehabilitation skilled professionals may only perform the initial and comprehensive assessment when only therapy services are ordered. This temporary blanket modification allows any rehabilitation professional (OT, PT, or SLP) to perform the initial and comprehensive assessment for all patients receiving therapy services as part of the plan of care, to the extent permitted under state law, regardless of whether or not the service establishes eligibility for the patient to be receiving home care.

More information on this waiver can be found at: COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers

4) Chapter One of the OASIS Guidance Manual reads:

- Start of care

- Resumption of care following inpatient facility stay

- Recertification within the last five days of each 60-day recertification period

- Other follow-up during the home health episode of care

- Transfer to an inpatient facility

- Death at home Discharge from agency

All of these assessments (listed above), with the exception of transfer to inpatient facility and death at home, require the clinician to have an in-person encounter with the patient during a home visit. A telehealth visit would be out of compliance.

The requirement for in-person assessment would be covered under:

G514 - Initial Assessment Visit/RN Performs Assessment