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OASIS-C Q & A

The National Association for Home Care and others have been submitting questions to CMS regarding the OASIS-C dataset. Below are some clarifications offered by CMS on the dataset. Thanks to Judy Adams for keeping us up to speed!

FALLS RISK ASSESSMENT

1. Does the falls risk assessment on the MedQIC website meet CMS criteria for “multi-factor” and “validated?”

CMS Response: The multi-factor falls risk assessment must include at least one standardized tool that (1) has been scientifically tested on a population of community dwelling elders and shown to be effective in identifying people at risk for falls and (2) includes a standard response scale. It is the agency’s responsibility to determine if the tools it is considering for the OASIS-C M item best practice assessments meet the requirements as detailed in Chapter 3 of the OASIS-C Guidance Manual and the CMS OASIS OCCB Q&As.

Note: The MedQIC tool referenced in Question #1 is the Missouri Alliance for Home Care’s screening tool. Based on CMS’ response, it does not meet validation requirements at this time. However, the Missouri Alliance is seeking validation of its tool, and NAHC will advise agencies once the process has been completed.

2. Does this risk assessment screening tool in the resources section of the OASIS C Guidance Manual meet the criteria of a standardized and validated tool? “Home Care Fall Reduction Initiative risk  Assessment Screening Tool (A multi-factor falls risk screening tool from the Missouri Alliance for Home Care, specifically designed for home care patients at Start of Care and Re-certification)” (Submitted by Fazzi Associates)

CMS Response:  The Missouri Alliance for Home Care (MAHC) tool, at this time, has not undergone the process of validation. The MAHC tool can be used in conjunction with a standardized, validated performance assessment like the TUG (Timed Up and Go) or Functional Reach Assessment to meet the requirements of the multi-factorial standardized validated falls risk assessment.

TOILETING HYGEINE

3. What if a patient has a new colostomy and is completely dependent on someone to empty the appliance (bag) as well as change the appliance but she can cleanse herself and care for her clothing with voiding? The patient usually changes the bag one to two times per week — unless there are problems. Is this patient a “0”? Are we interpreting correctly that the only way we would ever score this patient a “3” is if she is changing the appliance more often than she is voiding?

CMS Response: M1845-“Toileting Hygiene” assesses the patient’s ability on the day of the assessment to manage personal hygiene and clothing when toileting. If the patient has a colostomy, the hygiene would include cleaning (wiping) the perineal area after voiding and around the stoma when necessary. M1845 does not include the patient’s ability to manage the ostomy bag, stoma wafers, or other ostomy equipment. On the day of the assessment, if the patient has the ability to safely manage his or her clothing and perform the personal hygiene as described above, the appropriate score would be a “0”. How often the appliance (equipment) is changed does not factor into the scoring of this item.

OASIS-C FORMATTING

4. Is it permissible to add “hints” to our home-made OASIS C forms from the Chapter 3 OASIS item guidance to ensure continuity among our clinicians? In addition, is it permissible to indicate next to the “M” questions if they are a process item, non-routine supply item, Home Health Compare item, and outcome measure items?

CMS Response: Each agency may develop its own comprehensive assessments as it sees fit (including the addition of “hints” and other notations) as long as the assessment includes items that assess the patient’s continuing need for home care services and determine the patient’s medical, nursing, rehabilitative, social, and discharge planning needs; eligibility for the payer’s benefit; and the required OASIS items for patients that require OASIS data collection. The OASIS items must be incorporated into the assessment exactly as written, although skip patterns may be modified as needed if the agency chooses to change the sequence of the items. Refer to other CMS OASIS Q&As under Category 4a for further guidance related to formatting of the items into software.

PHYSICIAN DESIGNEE

5. Could a pharmacist be a physician designee for M2002-“Medicare Follow-up”?

CMS Response: A pharmacist is not typically a “physician- designee” in OASIS reporting. A physician designee is an individual who works in cooperation with and has been authorized by the physician (within his or her scope of practice) to facilitate care and communicate the physician’s orders. When completing the OASIS Medication process measure items, the pharmacist is only considered a “physician-designee” in a very limited situation. If, within one calendar day of identifying a clinically significant medication issue, the agency clinician communicates with the physician regarding the issue, the physician calls in a prescription change to the pharmacy causing the pharmacist to issue a prescription, then technically the pharmacist could convey the information. In this case, the clinician would still need to get an order from the physician

HIGH-RISK DRUG EDUCATION

6. For the assessing clinician to select a “Yes” response to M2010, must the high-risk drug education be provided on the actual start of care/resumption of care visit or can it be provided/completed on another visit by the same clinician within five days of start of care and two days of resumption of care? (Submitted by Fazzi Associates)

CMS Response: To respond “1-Yes” for M2010-“Patient/Caregiver High-Risk Drug Education,” the patient and/or caregiver must receive the specified education for all high-risk medications within the assessment timeframe. It is not required that it all occur on the actual start of care/resumption of care visit.

The education can be provided by clinicians other than the clinician responsible for completing the assessment. Please see the M2010 response-specific instructions in Chapter 3, which references how to handle situations where other agency staff is providing the education.

ASSESSMENT COMPLETION DATE

7. Does “assessment completed date” refer to information required to complete OASIS data items or any information contained within the agency’s comprehensive assessment? (Submitted by Fazzi Associates)

CMS Response: M0090- “Date Assessment Completed” is referring to the date the entire assessment was completed. The OASIS is just one component of the comprehensive assessment.

Coping with OASIS-C

As the year draws to close, the date for OASIS-C implementation is almost upon us. Are you ready?

Wait? Did you say, ‘yes’? I didn’t think so.

We have done this before and we will likely do it again. OASIS-C is huge. It will result in sweeping changes to our daily practice of nursing. And yet, you are hard pressed to find nurses confident in their ability to answer all questions correctly. That includes me, by the way. But if you are thinking that you will never be prepared and are considering resigning your position to work at Taco Bell then you may want to take a deep breath and rethink this.

I know from experience that we can teach and learn and reteach all we want but the real fun begins when the dataset is used for actual patients. Patients are mostly inconsiderate of our dataset and will frequently find a way to avoid fitting neatly into the little pegs in a dataset. One option is to discharge all of your patients. Better yet, post on the decision health listserv. Ask questions. Call your state association. Call or email a brilliant consultant. Or muddle through. The choice is yours.

This next point is critical. Pay close attention. It is very important.

You will fail as a home health nurse if you don’t change your processes. Your agency will fail as a company if it doesn’t change its processes. Our industry will fail miserably if we don’t change our processes.

Did that get your attention? Good. I have no appetite for failure. The only nurses I have ever met with a tolerance for failure never made it through the first year of clinicals.

Does that mean we have to be perfect on New Year’s Day? I hope not. I do not plan to be perfect until I at least know how! And I won’t know how until the data set is being used on real people.

Will you remember every detail taught to you in training? Will you be able to keep all the new processes straight? If you answered ‘yes’ you belong in an institution somewhere where your brain can be studied.

Having done this before with OASIS and OASIS-B and OASIS B-1, I have only one wish concerning the implementation of the new dataset. I wish that all of my colleagues will make the necessary changes in such a way that our patients truly benefit. As an industry we have to take these changes seriously. As nurses and caregivers, we have to minimize the time and energy we spend solely to accommodate a dataset. More importantly, there are millions of sick people in their home waiting for their nurses and aides and therapists to come make their lives better. Can we possibly do both?

I think so.

For updated OASIS-C training dates or onsite training information, please email us or call 225-216-1241.

Falls Assessment in OASIS-C

The OASIS-C dataset assesses whether or not the patient has had a fall risk assessment. In the item intent in Chapter 3 it further states that the multi-factor falls risk assessment that has been validated as effective in identifying falls risk in community-dwelling elders and which includes a standard response scale.

Although many falls risk assessments that meet these requirements are available, the one that is perhaps easiest to use and has been proven to be validated is the Timed Up and Go Test. This test uses only a chair and a tape measure and can be performed in just a few minutes. Patients who do not do well on a Timed Up and Go may be candidates for physical therapy and the use of this or a similar test will validate the patient’s need in a RAC audit.

We welcome your comments below or you can email us.

High Alert Medications

OASIS-C asks us if we have taught on high alert medications on admission and resumption of care.  The chapter 3 instructions state, “High-risk medications are those identified by quality organizations (Institute for Safe Medication Practices, JCAHO, etc.) as having considerable potential for causing significant patient harm when they are used erroneously.”

The link below is the list from the Institute of Safe Medication Practices.  It is the one we like best becaue it was originally designed for community pharmacies and doesn’t include medications only found in ICU’s and Operating rooms.  If you know of another list that might be worth taking a look at, please forward!

highalertmedications

As always, we welcome your comments below and your emails at haydelconsulting@haydelconsulting.com.

But Did You Call the Doctor?

Care Coordination is one of the most frequently cited deficiencies in state surveys. We seem to know the docs who don’t care about blood sugars out of parameters or won’t give wound care orders so we just don’t call them. Now, in addition to state surveys, the OASIS-C dataset will be looking at our communication with physicians.

Several questions in the OASIS-C dataset ask if the MD was notified in one calendar day. What the question really means is, “Did you notify the doc within one calendar day and get a response?” A fax confirmation is not a response for the purposes of this question!

And sometimes, the answer will be, ‘No’. No matter how hard you try or what action you take, sometimes, the physician or their designee will not be responsive. Consider a late Friday afternoon admission where a review of medications reveals that the patient is on both Zantac and Tagamet – a potential duplication of medications. You notify the MD after your admission and for some reason he doesn’t get back to you until Monday morning.

Many times, on call physicians leave all non-urgent calls for the patient’s regular physician. Some docs trust you to hold one of the meds until you hear back from them. Some docs are lazy and slow. And some, a very small minority, may not care.

So, what do you do? The way that these questions are phrased begs the ‘correct’ response of, ‘Yes’. And the same agencies that deliberately skew outcomes will undoubtedly have perfect scores on these questions. My clients will not. They have been taught to do their best and to answer according the events that take place in reality – not on Planet Julianne where every doc is doing nothing but sitting by the phone eagerly awaiting our phone calls.

And if anyone tells you to differently, remember that the OASIS-C dataset is a legal document with your signature on it. Take the time between now and the first of the year to educate referral sources. Since MD’s are also subject to outcomes, most will understand why you suddenly become so needy after the first of the year.

And if you look not so hot on paper, remember your choices are to be less than honest or devote an enormous amount of time to satisfying a dataset. In other words, look at your patient and do what needs to be done to take care of them and document appropriately. The last thing we need five years down the line is useless data because not everyone is answering the questions in the same way.

OASIS-C education is ongoing at our office and we would love to visit you onsite. If you are in need of staff training, please do not hesitate to call 225-216-1241 or email haydelconsulting@haydelconsulting.com.