10 days for comprehensive assessment? 5? 6?

I didn’t realize that the language in the OASIS Guidance Manual and the Conditions of Participation are slightly different, and that has caused some confusion with HHAs.

The Guidance Manual states that “At the start of care time point, the comprehensive assessment should be completed within five days of the start of care date”.

Conditions of Participation (484.55(b)) states that the assessment must be complete “no later than five calendar days after the start of care.”

Do you have 10 days … five days before and five after the SOC (using “within” to mean that in the OASIS manual?) Or five days … five calendar days, according to the CoP?

CMS has clarified that SOC is day zero, so you have six days to complete the assessment.

Here are a couple of examples where knowing this is useful and can keep you in compliance:

M2250 requires that the agency communicate findings to the physician and get orders for the best practices applicable, e.g., physician-ordered patient specific parameters, assessment and diabetic foot care. The agency has the 6 days to get the assessment done and get verbal orders back from the physician before you have to check ‘yes.’

M2010 requires that education be provided at SOC on high risk meds. You have those six days to complete teaching.

M0090 can be a day other than the day of initial visit … it can take more than one visit to complete the assessment.  Consider this example: You have a therapy-only case, and therapy does the initial eval on July 9; that’s the SOC. Therapy won’t do the OASIS, so nursing will come Monday the 11th.

The OASIS has to have a M0090 date of no later than the 14th. The therapist may do a falls risk assessment, but that doesn’t count toward the best practice. The falls risk assessment has to be completed by the assessing clinician within the timeframe of the SOC.

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