GG0170: CMS OASIS Q&As

If the car transfer activity (GG0170G) or the stair activities (GG0170M, N and O) are not completed because no car or stairs are available, and the patient’s status cannot be determined based on patient or caregiver report, collaboration with other agency staff, or assessment of similar activities, enter Code 10 - Not attempted due to environmental limitations. The assessing clinicians can use professional clinical judgment to determine if a car transfer, or stair activity, or other GG self-care or mobility activity, may be assessed using a similar activity as an acceptable alternative. For example, for item GG0170O - 12 Stairs, the combination of going up and down 4 stairs 3 times consecutively is an acceptable alternative to meet the intention of this activity.

At Start of Care/Resumption of Care (SOC/ROC), the mobility performance code is to reflect the patient’s baseline ability to complete the activity, and is based on observation of activities, to the extent possible. Clinicians may assess the patient’s performance based on direct observation (preferred) as well as reports from the patient and/or family, assessment of similar activities, collaboration with other agency staff, and other relevant strategies to complete all GG items. Each OASIS item should be considered individually and coded based on the guidance provided for that item. It is important to determine whether the appropriate code for each activity is a performance code (including Code 01 - Dependent) vs. an “activity not attempted” code. It is also important to note that a helper cannot complete the walking activities for a patient. A walking activity cannot be considered completed without some level of patient participation that allows patient ambulation to occur the entire stated distance for that activity. For instance, if even with assistance a patient was not able to participate in walking a distance of 10 feet, an “activity not attempted” code (rather than 01 - Dependent) would be selected.

When assessing and coding the GG0170 - Mobility activities allow the patient to complete each activity as independently as possible, as long as they are safe. For example, if the added difficulty of making two 90-degree turns while walking 150 feet affects the patient’s safety, then a helper(s) should provide assistance as needed to allow safe completion of the activity. If completing a 90-degree turn is unsafe even with assistance of 1 or more helpers, then consider the walking 150 feet with 2 turns activity to not have been completed and use the appropriate “activity not attempted” code.

If a patient is able to complete the activity using an assistive device without assistance, code as 06 - Independent.

The intent of GG0170E - Chair/bed-to-chair transfer is to assess the patient’s ability to transfer to and from a bed to a chair (or wheelchair). When assessing self-care and mobility activities, allow the patient to complete each activity as independently as possible, as long as they are safe. If the patient performed the activity during the assessment timeframe, code based on that assessment using the 6-point scale. If when allowed to complete the activity as independently as possible, the patient was able to complete the transfer activity with substantial to max assist safely, code 02 Substantial/maximal assistance.

No, in the scenario described the effort necessary to lift up off the bed does not count towards the toilet transfer in GG0170F - Toilet transfer. The intent of GG0170F - Toilet transfer is to assess the patient’s ability to get on and off a toilet (with or without a raised toilet seat) or commode once the patient is at the toilet or commode.

The intent of GG0170F - Toilet transfer is to assess the patient’s ability to get on and off a toilet (with or without a raised toilet seat) or commode once the patient is at the toilet or commode. In the scenario described, the assistance provided while ambulating to the bed should not be considered when coding the GG0170F - Toilet transfer activity.

The intent of GG0170G - Car transfer is to assess the patient’s ability to transfer in and out of a car or van seat on the passenger side. The performance code is to reflect the patient’s baseline ability to complete the activity, and is based on observation of activities, to the extent possible. The assessing clinician may, as needed, combine general observation, assessment of similar activities, patient/caregiver report, collaboration with other agency staff, and other relevant strategies to complete all GG items. In situations where specific equipment may not be available (e.g., 12 steps, a vehicle), the assessing clinician may determine that assessment of a similar activity adequately represents the patient's ability to complete the activity. This practice will serve to minimize the use of an “activity not attempted” code in favor of a performance code determined to represent the patient's status in the given self-care or mobility activity. While CMS does not provide specific parameters or a complete list of what is and is not an acceptable proxy activity, providers are expected to use clinical judgment in determining if the "similar activity" meets the intent of the target activity to make it a reasonable substitute when making a coding determination. Use of an “activity not attempted” code should occur only after determining that the activity is not completed, and that the performance code cannot be determined based on patient/caregiver report, collaboration with other agency staff, or assessment of similar activities, in conjunction with all current assessment findings. If, using clinical judgment, simulating the car transfer adequately represents the patient’s ability to transfer in and out of a car, code GG0170G - Car transfer based on the type and amount of assistance required to complete the activity.

The intent of the GG0170 walking items is to assess the patient’s ability to ambulate safely for each of the stated distances. a. If the helper is only required to manage the oxygen tank, pushing it to allow the patient to safely walk without additional assistance from the helper, code 04 - Supervision or touching assistance. b. If the patient can complete the walking activity safely only after a helper retrieves and/or sets up oxygen equipment necessary to perform the included tasks, code 05 - Setup or clean-up assistance. c. If the patient is able to set-up the oxygen and is able to safely complete the walking activity without requiring the assistance of a helper, the activity would be coded 06 Independent.

At Start of Care/Resumption of Care (SOC/ROC), the GG0130 - Self-Care and GG0170 - Mobility performance codes are to reflect the patient’s baseline ability to complete the activity, prior to the benefit of services provided by your agency staff. The patient may be assessed based on the first use of an assistive device or equipment that has not been previously used. The clinician would provide assistance, as needed, in order for the patient to complete the activity safely, and code based on the type and amount of assistance required, prior to the benefit of services provided by your agency staff. “Prior to the benefit of services” means prior to provision of any care by your agency staff that would result in more independent coding. Introducing a new device should not automatically be considered as “providing a service.” Whether a device used during the clinical assessment is new to the patient or not, code based on the type and amount of assistance that is required for the patient to complete the activity prior to the benefit of services provided by your agency staff. Communicating an activity request (“Can you walk to the door?”) would not be considered verbal cueing. If additional prompts are required in order for the patient to safely complete the activity (“Stay closer to your walker,” etc.), the assessing clinician may need to use clinical judgment to determine the most appropriate code, utilizing the Coding Section GG Activities Decision Tree.

The intent of the GG0170 stair items is to determine the type and amount of assistance required by a patient to go up and down the stairs, by any safe means. At Start of Care/Resumption of Care (SOC/ROC), the mobility performance code is to reflect the patient’s baseline ability to complete the activity, prior to the benefit of services provided by your agency staff. “Prior to the benefit of services” means prior to provision of any care by your agency staff that would result in more independent coding. In your scenario if the patient was not able to go up and down the stairs prior to the benefit of services provided by the agency, and the performance code cannot be determined based on patient/caregiver report, collaboration with other agency staff, or assessment of similar activities, use the appropriate “activity not attempted” code.

There is no requirement to assess a patient going up and down both a curb AND a step. However, coding GG0170M - 1 step (curb) with a 07, 09, 10 or 88 when a patient is unable to go up and down a curb results in skipping GG0170N - 4 Steps and GG0170O - 12 Steps. Providers may want to consider assessing the patient’s ability to go up and down 1 step in order to capture performance codes of 06 through 01 for one or more of the stair items if the patient can complete the activities with a railing.

Ascending and descending stairs does not have to occur sequentially or during one session. If the assessment of going up and down stairs, by any safe means, occurs sequentially, the patient may take a rest break between ascending and descending the 4 steps or 12 steps. While a patient may take a break between ascending or descending the 4 steps or 12 steps, once they start the activity, they must be able to ascend (or descend) all the steps, by any safe means without taking more than a brief rest break in order to consider the stair activity completed.

The intent of the item GG0170Q - Does patient use a wheelchair/scooter? is to document whether a patient uses a wheelchair or scooter at the time of the assessment. The code 0 - No would only be used if at the time of the assessment, the patient does not use a wheelchair or scooter under any condition. Although it is under infrequent conditions, in your scenario, the patient uses a wheelchair, therefore, GG0170Q would be coded 1 - Yes. Regarding GG0170R - Wheel 50 feet with two turns and GG0170S - Wheel 150 feet, if a patient does not complete the wheelchair activities during a home visit, determine the patient’s abilities based on the patient’s performance of similar activities during the assessment, or on patient and/or caregiver report. If you are unable to observe the activity, and you cannot determine their status on patient and/or caregiver report or on assessment of similar activities, then select the appropriate “activity not attempted” code.