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OASIS-C Summary of Changes

We have completed an initial review of the proposed OASIS-C changes compared to the current OASIS B-1 data set and summarized our findings below. As consultants, we have a opinions and a burning desire to share – and we do exactly that in the coming weeks. However, this post is limited to a simple outline of the changes as we see them. Because it is only an initial review, it is possible that we have minor omissions in our review and welcome any corrections. Furthermore, we will be preparing comments for CMS and as such, your comments and opinions are not only welcome but solicited in the coming weeks.

Clinical Records and Diagnosis

There are two new questions in the Clinical Record items (the section that deals with reasons for assessments, person completing assessment, etc.) These questions refer to the referral date for Start of care/resumption of care dates and the actual date that care began or was started. Currently, CMS has a 48 hour time frame between referral and admission and a 24 hour time frame for resumptions of care. Some states such as Louisiana mandate 24 hours between referral and admission.

The data collected regarding prior diagnoses has changed in its format. Additionally, the OASIS-C data set is asking for each inpatient procedure and associated ICD-9 code to be included.

The diagnosis coding for the episode remains in the same format with four columns including severity. As with the data set released for use last January, CMS does not ask for onset or exacerbation dates. This is not a CMS requirement but some Fiscal Intermediaries strongly suggest (read: require) O/E dates. Expect vendors who mass produce assessment tools to include it.

The Overall Prognosis, Rehab Prognosis and Life Expectancy questions are being replaced with questions regarding Frailty and Stability. Influenza and pneumococcal vaccination status are being assessed. Another new question is one that assesses if the plan of care includes guidelines for physician notification in the plan of care.

Only one question regarding living arrangements is included in this section. A more in depth assessment is found at the end of the assessment.

Sensory Assessment

The current question regarding the patient’s ability to hear and understand spoken language has been split into two separate questions – one regarding ability to hear and the other regarding ability to understand verbal content. The vision question that we are familiar remains unchanged.

Like vision, the question regarding pain remains unchanged but three other questions regarding pain have been added to assess whether or not a standardized tool has been used to assess pain and the presence and effectiveness of any pain management measures.

Integumentary Status

One of the most significant changes in that only unhealed pressure ulcers are noted. Instead of trying to explain the question, I have cut and pasted below:

Note that for the first time we are being asked about the number of ulcers that were present on admission. And all the teaching that has been done regarding ‘back-staging’ ulcers will no longer be necessary since the data set specifies non-epithelialized ulcers.

The language regarding stasis ulcers has been changed slightly but the assessment remains the same. This is also the case with surgical wounds.

MO440 is gone at last. A new question in it’s place assesses if the patient has any skin lesion or open wound other than ulcers or surgical wounds that receiving assessment and/or intervention. Diabetic foot care has also warranted two new questions.

Respiratory Status and Cardiac Status

The respiratory status assessment remains unchanged.

Two new questions regarding congestive heart failure have been added. One question asks if the patient exhibited any signs of failure indicated ny clinical heart failure guidelines including dyspnea, orthopnea, edema, or weight gain at any point. The second question assesses what if any actions were taken by the staff.


The questions regarding urinary incontinence are essentially unchanged with one major addition. The question assessing when urinary incontinence occurs now includes a response of ‘occasional stress incontinence’.

The bowel elimination/ostomy questions remain unchanged.

Neuro/Emotional Status

The questions regarding confusion, anxiety and cognitive function are unchanged. However, Depression is intensely assessed in the proposed OASIS-C. For instance, the data set asks if the patient has been assessed for depression using a standardized depression screening tool. It goes on to assess depressive symptoms reported or observed. Note this question is very much like the OASIS B-1 question with an important change in the order of responses. In the new data set, if the patient has no symptoms, the answer will be one. It also includes a response for ‘other’ signs or symptoms of depression. Two other questions follow investigating if there are interventions for depression.


In the published proposed data set there is no assessment of ‘prior’ ability – the patient status two weeks prior to admission for each point of assessment. Therefore, the responses of ‘unknown’ are not listed in the questions. However, there are two questions that investigate whether the patient is the same/better or worse at mobility and self car ability.

The questions regarding grooming, dressing upper and lower body, and bathing are the same. There are some changes in the question regarding toileting to specify that that toilet transferring is being assess. An additional question has been added to assess toileting hygiene which assesses if the patient is able to safely maintain perineal hygiene, adjust clothes and incontinence aids if used before and after using the toilet and cleaning and managing equipment.

The questions regarding transferring remains the same but an additional answer has been added to the question regarding Ambulation. The use of a one handed device as opposed to a two handed device (cane vs walker) is now assessed.

The question regarding feeding and eating is unchanged followed by the two questions regarding changes in mobility and self care ability referenced above.

Additional questions regarding fall risks are asked along with fall and fall risk interventions. A change in the ability to perform routine household tasks is assessed.

The questions regarding transportation, laundry and housekeeping do not appear to be in the proposed OASIS C data set.


The Medications assessment has been greatly expanded. A new question regarding the potential for adverse effects or reactions is asked first. Specifically, the question asks if the drug regimen review indicates a significant potential for adverse effects or reactions including ineffective drug therapy, side effects, drug interactions, duplicate therapy, omissions, dosage errors or non-compliance.

Next is a question investigating whether the MD was contacted within one calendar day to resolve clinically significant medication issues, including ‘reconciliation’. Two additional questions follow regarding patient and caregiver drug education.

The language in the question regarding patient ability to take oral, injectable and inhalant medications is slightly changed. The responses remain the same. There is an additional question that asks if the patient’s ability to take meds is better or worse than before the onset of illness that initiated the care episode.

Equipment Management

The question regarding the patient abilty to manage equipment remains unchanged but this section is where an in depth review the types and sources of the assistance the patient receives is assessed. Using a grid, the clinician is asked to evaluate the patients need for assistance in ADLs/IADLs, meds, other treatments or procedures, equipment management, supervision and advocacy. In the grid, responses assess whether or not assistance is needed and how likely the caregivers are to provide that assistance.


The therapy question remains unchanged. It still requires the number of therapy visits the patient will receive.

Emergent Care

The question regarding whether or not the patient received emergent care has been reduced to a simple ‘yes’ or ‘no’ response with an option for ‘unknown’. The reason for Emergent care has been expanded from 9 possible responses on the OASIS B-1 data set to 19 on the proposed OASIS C data set.

The familiar discharge disposition question that assesses whether or not the patient remained in the community is followed by a second question assessing how much assistance the patient requires after discharge and who is providing the assistance.

The hospitalization question also remains the same but like Emergent Care, the responses have been changed to reflect more conditions and expand the definition of current responses.

The two last questions on the current OASIS B-1 data set requiring the date of last home visit and transfer date are not listed on the OASIS C data set.

For further details, please click on the link to the left on your screen and review the proposed OASIS C data set in its entirety.

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