Even with unexpected discharge, M0090 rules

Question: I understand that for a transfer, or unexpected discharge, the data collected at the last skilled visit is used for the remote documentation.  However, we have had several instances of losing several HHA, PTA, and OTA visit reimbursements, as we are using the last skilled visit as the last billable visit. Is this correct?  Sometimes there are nearly two weeks of forfeited visits due to this rule, which we are not sure we are interpreting correctly.

Lisa says: Your HHA, PTA and OTA visits are billable and should be included on your claim. Completing the OASIS DC is a separate issue. The last qualified clinician who saw the patient has to complete the OASIS based on information obtained at that last visit. But remember that the M0090 date is still the date the assessment was completed which is after the other billable visits were provided.

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