M0090: CMS OASIS Q&As

The HHA has the overall responsibility for providing services, assigning ICD-10-CM codes, and billing. CMS expects that each agency will develop their own policies and procedures and implement them throughout the agency in a manner that allows for correction or clarification of records to meet professional standards. It is appropriate for the clinician to enter the medical diagnosis on the comprehensive assessment. The HHA can assign a qualified coder to determine the correct numeric code based upon the written diagnosis provided by the assessing clinician. The M0090 - Date Assessment Completed, is the last date that information used to complete the comprehensive assessment and determine OASIS coding was gathered by the assessing clinician and documentation of the specific information/responses was completed. The M0090 date should not necessarily be delayed until coding staff verify the numeric codes.

While a thorough review by a clinical supervisor may improve assessment completeness and data accuracy, the process for such review is an internal agency decision and is not required. The M0090 - Date Assessment Completed, is the last date that information used to complete the comprehensive assessment and determine OASIS coding was gathered by the assessing clinician and documentation of the specific information/responses was completed.

Under normal business practices, one home health visit should not include two types of assessments and be billed to two payer sources. The discharge date for the (RFA 09) Discharge from Agency should be the last date of service for the payer being terminated. The admission date for the new Start of Care (RFA 01) assessment should be the next scheduled visit, according to the Plan of Care. The agency may send a batch including both assessments to the OASIS system. An edit is in place at the OASIS system to sort for an assessment to close an open patient episode prior to opening a new episode.

M0090 - Date Assessment Completed, is the last date that information used to complete the comprehensive assessment and determine OASIS coding was gathered by the assessing clinician and documentation of the specific information/responses was completed. In most cases, but not all, M0090 is the day of a visit. Sometimes the clinician may gather information off site, or other items that are dependent on a call back from a caregiver or physician or other non-patient assessment data, like dates. M0906, Discharge Date, is defined by agency policy. For some agencies it is the date of the last visit, but other agencies may define it to be one or two days or more after the last visit. It is not prescribed by regulation, except that the discharge date cannot occur before the date of the last visit. Regulation requires that the discharge assessment must be completed within two calendar days of the actual discharge date or within two calendar days of learning of the need to discharge in the case of an unplanned or unexpected discharge. In the case you described, the discharge date (M0906) could be defined by the agency's policy as two days after the last visit to allow for the notice of non-coverage. The clinician would then have up to two calendar days after M0906 to complete the assessment (M0090). The bulk of the assessment items could be completed on the visit and then M0906 - Discharge date and M0090 - Date Assessment Completed (the last items you needed to complete the assessment) could be 2 days after the date of the last visit, once the discharge was a certainty. Establishing a policy that defines the discharge date in this way prevents the problem with the timing of the data submission and is compliant with the regulation.

If the original assessing clinician gathers additional information during the SOC 5 day assessment timeframe that would change a data item response, the M0090 - Date Assessment Completed would be changed to reflect the last date that information used to complete the comprehensive assessment and determine OASIS coding was gathered by the assessing clinician and documentation of the specific information/responses was completed. If an error is identified at any time, it should be corrected following the agency’s correction policy and M0090 would not necessarily be changed.

M0090 - Date Assessment Completed, is the last date that information used to complete the comprehensive assessment and determine OASIS coding was gathered by the assessing clinician and documentation of the specific information/responses was completed. The Condition of Participation, §484.55, requires that a drug regimen review be performed each time a comprehensive assessment is required. When the therapist has completed the SOC Comprehensive Assessment, and the agency has a nurse in the office review the med list, the M0090 date would reflect the last date that information used to complete the comprehensive assessment and determine OASIS coding was gathered by the assessing clinician and documentation of the specific information/responses was completed.