First Glance at OASIS – C Guidance
UPDATE: OASIS-C training has been scheduled for November 12th and 19th at our Education Center. Please call 225-216-1241 for more information on how to attend or how to schedule training at your location for your clinicians.
Like many of my colleagues, I spent the day reading the official OASIS-C Guidance Manual and got the first look at the instructions that accompany the dataset. And, of course, as predictable, at least one section (wound care) has already been pulled back for review by CMS. Obviously, we are not experts on the newly published guidance but after a first view, we did make some interesting observations and hope that you will share your observations with us as well. A link to the OASIS-C Guidance is published below.
We have new dates to record in the OASIS dataset. Within the context of the dataset, they appear as simple data points. Within the instructions, it appears as though the dates that are recorded are going to be very specific regarding admission/resumption of care dates. The dataset wants to know if the physician ordered a specific date for admission/ROC. If, not, the dataset wants the date that the agency received the verbal or written order to admit/resume care. Physician signed updates must be present to justify any deviance from the orders or expected compliance to state and federal rules.
What this means: By running a simple data check on collected OASIS data, CMS and state surveyors now have the ability to determine how long it is taking you between referral and admission/resumption of care. More importantly you will be able to determine if your patients are being admitted timely.
Although it should be a simple task to answer the four questions on vaccination status, a quick google search told us that there was no formal flu season. It is generally accepted to be between October and May. This year we have two varieties of flu striking at two different times. Do we answer the question without regard to H1N1 flu as we can reasonably assume that it wasn’t a known threat when the dataset was written?
The second issue is that CDC guidelines are referenced in vaccination questions. This will add the burden of the agency to research the vaccination guidelines each year as changes are made. When the flu vaccine is in short supply, the age range may change. Certain populations with compromised immunity may receive additional or split doses of one or more vaccine. The only way we will be able to clearly assess the vaccination status of our patient is to be current on the CDC Recommendations. Considering that 36,000 people die each year from the flu, this may not be too much of a burden to nurses.
There are several questions which assess an agency’s use of formal assessment tool. The use of this information is to capture the agency’s use of best practices following the admission/ROC assessment. The OASIS Guidance stresses that CMS does not mandate the use of any tool, nor does it recommend one tool over any other. Hint: CMS may not mandate the use of these tools but only an agency that does not want to succeed will ignore the blatant hint to do so.
And this isn’t a bad idea. We need to educate staff to collect consistent data during assessments across time periods so we can measure our success. After CMS will be measuring our success and publishing it for all of your referral sources, patients, state surveyors and the odd curious person with an internet connection. The only formal assessment that is actually included in the OASIS dataset is a depression screen comprised of only two questions. The first question assesses for how long the patient has been bothered by little interest and pleasure in doing things and the second assesses if the patient is feeling down, depressed and hopeless. By my early calculations, approximately all of our patients will meet the standard for depression on admission. Although it is still very early, it is likely we will search for another tool for agencies to use in place of the screen included in the dataset.
Medications are intensely assessed in the OASIS-C dataset. Again, this is a first glance, but my first impression is that the instructions provided in the OASIS-C guidance are confusing. It appears that agencies will both have to learn and to collect data on adverse events. Currently, most of our clients complete adverse reaction forms for truly serious medication errors and the dataset is asking for information on missed medications, etc.
Also, within this set of questions (as well as some others), physician notification is defined clearly. The physician notification can be by fax, phone, email, etc. but there must be verification that the physician received the communication. Whether or not orders were adjusted will also be assessed and data collected.
This certainly isn’t the last you have heard from us on the new dataset and the published Guidance. We have been asked by our State OASIS coordinator not to teach prior to their training. Apparently, this request came from CMS. However, early next year come meet me in Chicago at the Ultimate OASIS-C and Coding training series presented by Decision Health. More information can be found here: www.homecarecoders.org/ultimate training.
Again, we also want to know what you think so please feel free to call us at 225-216-1241 or email us at firstname.lastname@example.org.