M0100: CMS OASIS Q&As

If you complete and transmit the RFA 6, Transfer to an inpatient facility - patient not discharged from agency, and the patient does not return to the care of the agency during the current 60 day certification period, no further OASIS is required. The quality episode ended with the Transfer (RFA 6) that was completed. You do not need to cancel the RFA 6 and resubmit the RFA 7, just complete your agency's internal discharge paperwork.

Yes, if the patient was admitted to an inpatient facility bed for 24 hours or longer for reasons other than diagnostic testing, a Transfer OASIS is required. Respite care is more than diagnostic testing and the response to M0100 - Reason for Assessment (RFA) is RFA 6 or 7, Transfer to an inpatient facility. If the agency anticipates the patient will return to their care after the inpatient stay, RFA 6 - Transferred to an inpatient facility - patient not discharged from agency should be completed. RFA 7 - Transferred to an inpatient facility - patient discharged from agency will be selected if the agency does NOT anticipate the patient will return to their care.

A Transfer OASIS is required when the patient has been transferred to an inpatient bed for 24 hours or longer for reasons other than diagnostic testing. If the patient was admitted to one inpatient facility bed then transferred to another, the Transfer OASIS would be required once a total of 24 hours have been spent as an inpatient, under an inpatient billing status. In the situation described, a Transfer is required once the patient was inpatient for a total of 24 hours, in one or more inpatient facilities.

Yes, when calculating the days, you have to complete the comprehensive assessment, the SOC date is day “0”. For the other time points the date of reference (e.g., transfer date, discharge date, death date) is day “0”. Note that for the purposes of calculating a 60-day certification period, the SOC day is day “1”.

No, under the circumstances described, the patient did not meet the OASIS transfer criteria of admission to an inpatient facility for reasons other than diagnostic testing, if the patient, indeed, did not have any other treatment other than diagnostic testing during their hospitalization. If the patient received treatment for the abnormal test result, then the situation, as described, would meet the criteria for RFA 6 or 7, Transfer to inpatient facility.

In the scenario described, the Transfer OASIS (M0100 - RFA 7 – Transferred to an inpatient facility – patient discharged from agency) would be completed to end the patient’s quality episode. The M0906 date would be the date the patient transferred to the hospital (July 28th), and the M0090 - Date Assessment Completed would be the day that information used determine OASIS coding was gathered by the assessing clinician and documentation of the specific information/responses was completed. The Transfer OASIS is due within two calendar days of the qualifying transfer to an inpatient facility. OASIS not completed according to the required timeframes represents noncompliance with the data collection rules.

Diagnostic testing refers to tests, scans and procedures utilized to yield a diagnosis. Cardiac catheterization is often used as a diagnostic test to determine the presence or status of coronary artery disease (CAD). However, a cardiac catheterization may also be used for treatment, once other testing has established a definitive CAD diagnosis. Each case must be considered individually. by the clinician without making assumptions. The fact that the procedure requires anesthesia does not determine whether or not the procedure is purely diagnostic or not. Utilizing the definition of diagnostic testing, a clinician will be able to determine whether or not a certain procedure or test is a diagnostic test.

In order to qualify for the Transfer to Inpatient Facility OASIS assessment time point, the patient must meet 3 criteria: 1) Be admitted to the inpatient facility (not the ER, not an observation bed in the ER) 2) Reside as an inpatient for 24 hours or longer (does not include time spent in the ER) 3) Be admitted for reasons other than diagnostic testing only In your scenario, you are describing a patient that is admitted to the inpatient facility and stays for 24 hours or longer for reasons other than diagnostic testing. An admission to an inpatient facility for observation is not an admission for diagnostic testing only. This is considered a qualifying inpatient hospitalization. The correct M0100 - Reason for Assessment (RFA) response would be either RFA 6 -Transfer to an inpatient facility - patient not discharged from agency or RFA 7 - Transfer to an inpatient facility - patient discharged from agency, depending on whether the agency anticipated the patient would return to their care (RFA 6) or not (RFA 7). M2410 - To which Inpatient Facility would be answered with Response 1 - Hospital as you state the patient was admitted to a hospital.

For purposes of M2301 - Emergent Care, Response 1, Yes, used hospital emergency department WITHOUT hospital admission, is the appropriate response for a patient who was held in a hospital emergency department for outpatient observation services without a subsequent qualifying hospital admission. A qualifying hospital admission is an admission to a hospital inpatient bed for 24 hours or longer for reasons other than diagnostic testing. A Transfer OASIS is not required. If, from observation status, the patient was eventually admitted to the hospital as an inpatient and the transfer criteria were met, the Transfer OASIS would be required. The agency would complete RFA 6 or RFA 7 data collection, depending on whether they anticipated the patient would return to their service (RFA 6) or not (RFA 7). During the period the patient is receiving outpatient observation care, the patient is not admitted to a hospital. Regardless of how long the patient is cared for in outpatient observation, the home care provider may not provide Medicare billable visits to the patient at the ER/outpatient department site, as the home health benefit requires covered services be provided in the patient's place of residence. If the patient is not admitted to the hospital, but returns home from the emergency department, based on physician orders and patient need, the home health agency may continue with the previous or a modified Plan of Care. An Other Follow-up OASIS assessment (RFA 5) may be required based on the agency's Other Follow-up policy criteria.

The requirement for the RN to complete an initial assessment visit prior to therapy visits in multidisciplinary cases is limited to the SOC time point. At subsequent time points, including the ROC, either discipline (the RN or PT in the given scenario) could complete the ROC assessment. In the situation described, while the ROC visit and assessment must be completed within 48 hours of the patient’s return home from the inpatient facility, there is no requirement that other services be delayed until the assessment is completed. Therefore, assuming compliance with your agency-specific policies and other regulatory requirements, there is no specific restriction preventing the PT from resuming services prior to the RN’s completion of the ROC assessment.

An RFA 6 or 7, Transfer to an inpatient facility, is required any time the patient is admitted to an inpatient facility for 24 hours or longer for reasons other than diagnostic testing. The fact that it was a planned admission is not a factor in determining if the Transfer OASIS data collection and submission are required. The patient who goes routinely into an inpatient facility for chemotherapy would require an RFA 6 or 7, Transfer to an inpatient facility, if they are admitted to an inpatient for 24 hours or longer since they are receiving treatment and not just diagnostic testing. If a patient is admitted for diagnostic testing only and does not receive treatment, they do not require an RFA 6 or 7, Transfer to an inpatient facility, no matter how long they stay in the inpatient facility. If it was a planned admission for diagnostic testing and the patient ends up receiving treatment, a Transfer would be required if the stay in the inpatient bed is for 24 hours or longer.