Agencies now have more details about how CMS would like them to respond to revised OASIS-C1 items including falls risk, worsening in pressure ulcer status and plan-of-care synopsis items.
 
Those details were included in the July 10 release of the draft Chapter 3 of the new OASIS-C1/ICD-9 guidance manual. The biggest changes in the guidance manual relate to those OASIS items that were changed or added in the final OASIS-C1 assessment. They include M1910 (Falls risk assessment), M1309 (Worsening in pressure ulcer status since start of care (SOC)/resumption of care (ROC) and M2250 (Plan of care synopsis).
 
CMS released its draft OASIS-C1/ICD-9 version on June 17 that includes changes to accommodate ICD-9 coding items that exist now in light of the ICD-10 delay. CMS plans to post a final version of the OASIS-C1/ICD-9 guidance manual after the Office of Management & Budget (OMB) approves the OASIS-C1/ICD-9 version data item set.
 
Highlights from OASIS guidance
  • M1910. Guidance states clinicians must use at least one "standardized, validated" tool in the multi-factor falls risk assessment, not simply a "standardized tool" as the 2012 OASIS-C manual indicates. If the tool chosen by the agency only has a single threshold separating those "at risk" from those who are not, then the patient scoring "at risk" should be scored as response "2 - Yes, and it does indicate a risk for falls." (See more details in Section K "ADLs/IADLs.")
  • M1309. CMS broke this item out from the old M1308 to capture pressure ulcers that are unstageable due to slough/eschar and that are new or previously Stage I or Stage II at the most recent SOC/ROC. Response option "d-Unstageable due to coverage of wound bed by slough or eschar" should be used to define unstageable pressure ulcers due to slough or eschar as those in which the wound bed is not visible due to some degree of necrotic tissue or scabbing the clinician believes may be obscuring the visualization of bone, muscle, tendon or joint capsule. If a Stage IV structure is visible, the pressure ulcer is not considered unstageable; it is a Stage IV even if slough or eschar is present, the guidance states. (See more details in Section F "Integumentary status"
  • M2250. The draft guidance manual adds language to the "NA" response for M2250 to say that a patient has no depression and depression screening indicates the patient has: 1) no symptoms of depression; or 2) has symptoms but does not meet criteria for further evaluation of depression based on the screening tool used. (See more details in Section N "Therapy need plan of care.")
Related link: The draft OASIS-C1/ICD-9 guidance manual can be found here.
 
Training opportunity: Get a complete breakdown of the guidance manual by signing up for DecisionHealth's webinar "Comply with new OASIS-C1 guidance and submission process, ensure proper payment" on July 31, 1 to 2:30 p.m. Get details at: http://www.decisionhealth.com/conferences/A2528/.