An update to the language found under M0030 (Start of Care Date) was included in the draft version of the OASIS-E1 instrument, released earlier this month. OASIS-E1 is set to take effect Jan. 1, 2025. 
 
The updated guidance addresses agencies whose policies require an RN to perform the non-billable nursing assessment for therapy-only cases. 
 
Under the guidance for this item, CMS plans to add: When the agency’s policy/practice is for an RN to perform the SOC assessment in a therapy-only case and the therapist’s first visit is the start of care date (i.e., the first billable visit), the non-billable nursing assessment visit must be made the same day or within five days after the therapist’s first visit. 
 
While this is not new guidance itself, it will be a new addition to the OASIS-E1 guidance manual. 
 
There are currently no states that require agencies to have an RN perform the assessment and it is not a policy that is commonly seen anymore, notes Cindy Krafft, co-owner and founder of K&K Solutions of Fernandina Beach, Fla. 
 
“I have never understood why agencies would provide a nursing visit that will not be paid for to do this,” Krafft says. “Therapists with proper training are fully capable of completing this.” 
 
And for those agencies looking to change this policy, it could be as simple as updating any policy/procedure related to the SOC to include both nursing and therapy available to conduct the OASIS, Krafft advises. 
 
For more on the new OASIS-E1 draft guidance manual, see here. — Megan Herr (megan.herr@decisionhealth.com)  
 
Editor’s note: To view the latest draft of the OASIS-E1 guidance manual, see https://tinyurl.com/htdyj7et.