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he purpose of the Outcome and Assessment Information Set (OASIS) and your agency’s integrated assessment is to provide a complete picture of the patient. Because many clinicians still struggle with documenting an assessment by answering multiple-choice questions, it is easy to end up with inconsistencies between the various OASIS questions. In this article, we will discuss some of the most frequently seen discrepancies.
       M0175 (“From which of the following inpatient facilities was the patient discharged during the past 14 days”) has several comparison points and is currently being evaluated by the Centers for Medicare and Medicaid Services (CMS) Office of the Inspector General (OIG) for incorrect responses. This question is a “mark all that apply,” so if the patient was admitted to the hospital then sent to a skilled nursing facility where he or she was an inpatient for seven days, both hospital (option 1) and skilled nursing facility (option 3) would be selected. While this may seem pretty straight forward, some hospitals have skilled nursing beds within their hospital; in this example, a patient would need both option 1 and 3 marked even though he or she may have stayed in the same building. A careful evaluation must be completed. Also, be sure that M0175 is consistent with M0180 (inpatient discharge date) as well as any surgery or procedure date, because most of these are completed in the inpatient setting.
       Another challenge is presented with the neuro/emotional/behavior status questions (M0610, 620, and 630), because we are only in the patient’s home for a short time when we complete them. Use the following comparisons to determine if inconsistencies exist in your agency’s assessments:
• Little or no abnormal behaviors are indicated (M0610), but psychiatric services are being provided (M0630).
• The patient is reported to be confused (M0570) or anxious (M0580) daily or all the time, yet memory deficit or impaired decision making (option 1 and 2 of M0610) is not indicated.
       One other area overlooked is well approximated, healing surgical incisions (M0482, 484, 486, and 488). If a patient has a surgical procedure date done less than a week prior to the assessment date and presents with a clean, dry incision secured with steri-strips, deciding its healing status (M0488) is largely based on status of the healing ridge, which is defined as a palpable, indurated, 1cm-wide area around the incision line. A healing ridge typically develops within five to nine days of surgery and persists until day 15 post-surgery (though it may differ from patient to patient). In the above scenario with the surgery less than a week ago, a clinical assessment would likely find that the healing ridge was not well defined and thus the surgical wound status (M0488) would be “early/partial granulation.” So check M0488 against any surgical procedure dates. Because the primary focus of therapists is functional status versus skin assessment, additional education may need to be provided.
       Additionally, evaluate any patient who has one of the activities of daily living (ADL) status questions (M0640 through M0700) marked with option 3 or 4 (requiring significant assistance for the specific activity) and another marked as 1 or 2 (able to perform with little or no limitations). This is an unlikely combination of functional abilities. For example, patients who can transfer with minimal assistance (option 1 in M0690) typically are not entirely dependent upon another person to dress the lower body (option 3 in M0660).

Frequently Asked Questions
       Question: What is the new branch identification number?
       Answer: To help CMS and state agencies separately identify quality issues in branches separate from parent agencies for survey purposes, a unique branch identification number will be assigned. This identification number will not replace existing Medicare provider numbers and will not be used for billing purposes. This number will be indicated on OASIS assessments in locator M0016 and is required starting January 1, 2004. Each branch will be assigned an identification number that includes the same federally assigned provider number as the parent or subunit with two modifications. There will be a “Q” between the state code and four digit provider designation plus three more characters after the last four digits of the parent’s provider number for a 10-digit branch identifier. For example, XYZ agency in Alabama has three branches. XYZ’s provider number is 017001. XYZ’s branches would be assigned the branch identification numbers 01Q7001001, 01Q7001002, and 01Q7001003.
       Generally, the agency does not need to do anything to receive the number, as the state agency or regional CMS office will mail the branch identification assignment letter to the parent agency address. However, the parent agency could receive a questionnaire from either the state agency or regional CMS office that must be completed and returned to the sender prior to receiving the branch identification assignment letter. CMS central office has indicated that it expects all of the numbers to be issued by the end of the year.
       Question: If M0420 (“frequency of pain interfering with patient’s activity or movement”) is answered option 2 (daily, but not constantly) or option 3 (all of the time), should M0430 (“intractable pain”) be answered with option 1 (yes)?
       Answer: Each OASIS question should be answered on its own. While it is likely that if you have pain all the time, it will be intractable, just because it is daily does not mean that it is intractable.
       Question: Last year we had a patient on service for wound care for a stage 3 pressure ulcer and discharged after three months to self wound care management. The pressure ulcer subsequently healed completely. The patient’s diabetes had advanced from oral management to insulin dependent, and last week, we readmitted the patient to teach him safe and effective insulin administration. We indicated there was not a pressure ulcer. Was that correct?
       Answer: No, the CMS guidelines for OASIS do not recognize down staging or reverse staging of pressure ulcers, even after they have healed and a scar has formed. Thus, upon readmission, indicate a stage 3 pressure ulcer (M0450, 460) with a status of fully granulating (M0464). Because this will increase your Home Health Resource Group (HHRG), documentation of the previous pressure ulcer, physician documentation, or previous admission information is key to substantiate these answers and to prevent potential downcoding later.
       If you have a question that you would like addressed in “OASIS: More Than Just an Assessment,” call Renee Olszewski, Managing Editor, at (800) 237-7285, extension 209, with your question, or e-mail it to rolszewski@hmpcommunications.com and we will address it in a future issue.