Posts tagged ‘comprehensive assessment’

November 5, 2010

An example of clinicians doing the skilled visit and comprehensive assessment

I posted late Tuesday on clinicians doing a skilled visit and the comprehensive assessment. I’ve received several requests for an example, so here you go!

A referral on a patient requires a visit at 10pm to administer an IV antibiotic. An RN can make the visit at 10pm, providing the skillled care and performing the initial assessment (determine immediate care needs and homebound status). That visit qualifies as the SOC because a reimbursable service was provided. Another RN can make a visit the next day (or within 5 days after the SOC) to complete the OASIS comprehensive assessment.

November 2, 2010

Separate clinicians can do SOC OASIS and ‘first visit’

It seems that many agencies believe that the SOC OASIS needs to be done by the same clinician who did the first visit, but that’s not true.

The initial assessment does not have to done by the same person who does the comprehensive assessment. Most times, it is the same person because both assessments are completed during the same visit, but the CoPs allow for the initial assessment  being performed at a different visit.

Remember that if nursing is involved in the POC, an RN must conduct both assessments. In some instances, it may be a therapy only case, the therapist may complete the initial assessment and the RN may visit on the same day or within five days after the therapist’s visit to complete the comprehensive assessment.

August 23, 2010

M1240 … a pain to get right?

Pain is such a subjective subject, and I’ve heard from many clinicians who wonder how to answer M1240 correctly … does it refer only to severe pain? When does pain qualify? So let’s look at the question, then at ways to assess.

M1240: Has the patient had a formal pain assessment using a standardized pain assessment tool (appropriate to the patient’s ability to communicate the severity of pain)?
0: No standardized assessment conducted
1: Yes, and it does not indicate severe pain
2: Yes, and it indicates severe pain

The OASIS Guidance Manual tells us that this item’s intent is to see if a standardized assessment was conducted, and what the level of pain was, if, and only if, the assessment was conducted.

The item’s intent deals with the assessment, and CMS has stated that clinicians should assess for “any and all pain the patient experiences.” (April 2010)

When dealing with M1240, watch M2250 (Plan of Care Synopsis) and M2400 (Intervention Synopsis).

M2250 is where it would be noted if the doctor ordered interventions and monitoring for the pain. Only mark NA if the patient is not experiencing pain. (That’s NO PAIN AT ALL.)

August 13, 2010

M0090, M1350, and M2004 questions answered

Here are answers to three recent questions that I have fielded on OASIS:

For M0090, we’ve heard that is the date that we  (RNs) complete the OASIS assessment, including getting frequency from PT, OT, ST, and response from MD if any abnormalities with meds are found … this occurs all in a five-day window. Others are teaching to put the M0o90 date as the date we (RNs) complete the assessments without info from others. How do we fill this item?

Lisa says: The assessing clinician has six days to complete the SOC assessment.  (Assessment is day zero + five days.) This time period includes collaboration with other clinicians, i.e., M2200, and waiting for the physician’s response for M2250. M0090 is the date the assessment is completed, and it is not complete until that info has been received.

If you address a wound under Wound 1 in M1350, do you answer as a ‘yes’? Or does this question only apply to the previous questions about ulcers. If you have a PICC line that you address later in the SOC, do you answer M1350 as ‘yes’?

Lisa says: M1350 includes any wounds or skin lesions OTHER than the pressure ulcers, stasis ulcers, surgical wounds already addressed, and bowel ostomies, which are also addressed in another item. The answer ‘yes’ on M1350 means that the skin lesion or wound requires intervention and assessment. PICC lines that require intervention ARE included.

Let’s say that the SOC and DC OASIS are all that were completed when answering M2004. You answered it as ‘no’ on the SOC because you did not receive a response from the MD in 24 hours, you have addressed all issues, and no new issues have appeared. Do you answer this as ‘NA’ or ‘no’ if the MD did not respond in the 24 hours from the SOC OASIS?
Lisa says: If the physician does not respond within one calendar day (which can be longer than 24 hours, given the way CMS has defined it) the answer has to be ‘no’ on M2004. If there were no issues identified, then ‘NA’ would be the correct answer. Keep alert to news on this, as some recent CMS guidance could muddy this answer.

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July 19, 2010

CMS proposes payment changes to HH services for 2011

CMS is proposing major changes in therapy qualifications, documentation and “effectiveness” of therapy in the 2011 proposed HHPPS rule. It is also proposing case-mix changes and payment changes.

This post gives an overall view and focuses on payment aspects.

The Centers for Medicare & Medicaid Services (CMS) announced late last week in its Home Health Prospective Payment System Rate Update for Calendar Year 2011 Proposed Rule a number of changes for HHAs and Hospice regarding certification, case-mix, therapy and skilled service documentation and requirements, and payment rates.

The proposed rule has a 4.75 percent decrease in Medicare payments to home health agencies (HHAs) for calendar year (CY) 2011. Based on updated data analysis, instead of the planned 2.71 percent reduction for CY 2011, CMS proposes to reduce HH PPS rates by 3.79 percent in CY 2011 and an additional 3.79 percent in CY 2012.

The agency estimates that this could be a $900 million decrease compared to payments HHAs received in CY 2010.  The decrease is a combination of market basket update, a wage index update, reductions to the home health prospective payment system (HH PPS) rates and other factors.

The Affordable Care Act (ACA) mandates a 1 percentage reduction to the CY 2011 home health market basket amount. The ACA also changes the existing home health outlier policy through a 5 percent reduction to HH PPS rates, with total outlier payments not to exceed 2.5 percent of the total payments estimated for a given year.

Among the proposals that could help lower payments is a proposal to pull two hypertension codes, 401.9 and 401.1, from the case-mix list. CMS is also proposing far more specific, and restrictive language regarding therapy. The proposals include clarifications on the roles and duties of therapists and assistant, specifics on therapy for rehabilitation or maintenance that moves toward written goals, that all therapy visits must be considered reasonable and necessary, and what constitutes assessment, documentation and goals.

“The new HH PPS provisions will help ensure more accurate payments under Medicare and reflect prudent financial stewardship of the Medicare Trust Fund,” said Jonathan Blum, director of the Center for Medicare and deputy administrator for CMS.

In CY 2010, CMS finalized a policy that requires HHAs that change ownership within three years of initial enrollment to obtain a new State survey or accreditation.  CMS now proposes exceptions to the 36-month provision for certain types of ownership transactions.  CMS is also clarifying the quality reporting requirements for the CY 2012 HH PPS rate update, as it relates to the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) Survey.

Home health payment rates are updated annually by the home health market basket percentage increase.  CMS uses the home health market basket index, which measures (and tracks) inflation in the prices of an appropriate mix of goods and services included in home health services.

Read my post on the HTN case-mix proposal.

Read my post on proposed documentation and therapy roles.

Read about CMS’s specific skilled services wording aimed at reasonable and necessary therapy.

Find out more at

Read the full proposed rule.

Comments are being accepted until Sept. 14 on this proposed rule, CMS-1510-P. To send comments, go to  Follow the instructions under the “More Search Options” tab.

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