CMS provides further guidance on answering N0415 (High-risk drug classes: use and indication) — an item that has raised a lot of questions for clinicians in the early days of OASIS-E. This new information was part of 13 answers in the first quarter OASIS Q&As, released Jan. 17.
 
“Combination medications should be coded in all categories/pharmacologic classes that constitute the combination, regardless of why the medication is being used,” CMS clarifies.
For example, Percodan is a combination medication (oxycodone and aspirin) classified as both an opioid and antiplatelet.
 
“Therefore, for both N0415H (Opioid) and N0415I (Antiplatelet), Column 1 – ‘Is taking’ would be checked, regardless of why the medication is being used,” CMS further explains.
 
CMS also answers what sources are acceptable for determining patient-specific indications for N0415. “Sources include medical records received from facilities where the patient received health care, the patient’s most recent history and physical, transfer documents, discharge summaries, medication lists/records, clinical progress notes and other resources as available,” CMS states.
 
“Discussions (including with the acute care hospital, other staff and clinicians, the patient and the patient’s family/significant other) may supplement and/or clarify the information gathered from the patient’s medical records,” CMS says. There is not exhaustive list of examples for determining source. It’s up to clinicians to find resources and use their clinical judgement.
 
More OASIS-E answers
 
The January Q&As also include information on the following:
  • Rationale for having to use multipliers in D0160 (Total severity score).
  • Who would be considered a proxy. A number of new items under OASIS-E (A1005 (Ethnicity), A1010 (Race), A1110 (Language) and A1250 (Transportation) state that a proxy can be used.
  • Guidance about how “baseline” is defined at discharge for C1310A (Acute onset mental status change).
  • Whether a bowel cleanse is considered a mechanically altered diet for K0520 (Nutritional approaches).
 For further coverage of the latest release of OASIS Q&As, see the upcoming issue of Home Health Line.
 
View CMS’ January 2023 quarterly OASIS Q&As here.