OASIS · CMS Q&As
M1028: CMS OASIS Q&As
5 questions CMS has answered, quoted whole from the CMS OASIS Q&As and the 2026 quarterlies.
M1028 on the OASIS item lookup
M1028. For M1028 (Active Diagnosis) and other IMPACT ACT added items, what do I record on the paper instrument if I could not assess or did not have the information at the time of the assessment? I realize I would submit a dash (-) in the electronic submission. I understand the circumstances in which a dash is appropriate per the Guidance Manual. So, I don't need any guidance of when to use the dash. However, there is NO dash on the paper instrument. I would feel uncomfortable submitting something electronically that does not appear on the paper instrument. So, which takes precedence? The paper instrument, which does NOT allow a dash, OR the electronic data specs which allow a dash?
For OASIS items that allow the dash (–) as a valid option, the clinician should enter a dash in the applicable box on the agency’s paper or electronic assessment. CMS expects dash use to be a rare occurrence.
[Q&A ADDED 10/16; Previously CMS Qtrly Q&A 10/16 Q5]
M1028. Regarding M1028 - Active Diagnoses, according to the OASIS Guidance Manual, if information regarding active diagnoses is learned after the end of the assessment timeframe, the OASIS Data Set should not be revised to reflect this new information. The OASIS Data Set should reflect what was known and documented at the time of the assessment. My patient’s referral states that the patient is pre-diabetic. On the third day (still within the 5 days for the assessment) new information is received that the patient is being considered diabetic and orders are received. Can M1028 be changed based on this new information? Or should it not be changed because information was obtained after the admission?
Each assessment type has a defined timeframe for completion as specified in the OASIS Guidance Manual. Information collected by the assessing clinician during the timeframe for the specified assessment type should be documented and 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 the scenario cited, if the clinician confirmed the diagnosis of diabetes during the assessment timeframe and before the assessment was completed, reporting M1028 - Active Diagnoses as Response 2 - Diabetes Mellitus (DM) would be appropriate.
[Q&A EDITED 05/22; EDITED 10/18; ADDED 10/16; Previously CMS Qtrly Q&A 10/16 Q7]
M1028. In M1028, I need clarification on the term "active diagnoses." Specifically, when would a diagnosis of DM, PAD or PVD that is reported in M1021 - Primary Diagnosis or M1023 - Other Diagnoses not be reported in M1028 - Active Diagnoses as well? Are active interventions (treatments) on the POC required, or is it enough that the diagnosed condition justifies general monitoring/assessment? For example, a patient is admitted to home health for physical therapy s/p total hip arthroplasty. The patient is also a type 2 diabetic. The patient’s diabetes is controlled by diet and they are independent with monitoring their blood sugars. The patient is knowledgeable about diabetic foot care & checks their own feet daily using a mirror. Because the change in activity could affect the patient’s blood sugar levels and because the diabetes could affect their ability to heal from surgery, DM meets the selection criteria for a secondary diagnosis and would be reported in M1023. While the PT will be monitoring the patient holistically to identify problems and modify the plan of care as appropriate with physician collaboration, the PT orders do not list any active interventions related to the DM. Should DM be reported in M1028 as an Active Diagnosis?
"Active diagnoses" are diagnoses that have a direct relationship to the patient’s current functional, cognitive, mood or behavior status; medical treatments; nurse monitoring; or risk of death at the time of assessment. Diseases or conditions that have been resolved are not included for M1028 - Active Diagnoses. In the scenario cited, it is stated that the patient has a diagnosis of diabetes which could be affected by the patient's currently limited mobility, and/or could impact the healing of the patient’s surgical incision(s). The home health provider's monitoring of the patient/wound healing with specific knowledge that the patient is a diabetic, would make diabetes an active diagnosis for this patient.
[Q&A EDITED 05/22; ADDED 10/16; Previously CMS Qtrly Q&A 10/16 Q8]
M1028, M1021, M1023. Is it possible that DM, PAD or PVD would be identified as an Active Diagnosis in M1028 but not be included as a primary or secondary diagnosis in M1021 or M1023? For example, a patient is referred to home health for speech language pathology interventions related to dysphagia. The patient also has PAD which is documented in the patient's medical history. However, the PAD, while identified in the physician's summary/notes, does not meet the selection criteria for inclusion as a primary or secondary diagnosis as the SLP has no interventions related to the patient's PAD nor is it felt to have an impact on the patient's prognosis related to the dysphagia. Should the PAD be reported in M1028 - Active Diagnoses?
In the scenario cited, you ask if it is possible for DM, PAD or PVD to be considered an Active Diagnosis in M1028, but not be reported as a primary (M1021) or other (M1023) diagnosis. In the scenario cited, while the patient has the diagnosis of PAD, the clinician is determining that the PAD is not the chief reason for home health services (not the primary diagnosis), and is not a comorbid condition that is addressed in the plan of care, and isn’t felt to have the potential to affect the patient’s responsiveness to treatment (not a secondary diagnosis). Therefore, for this patient, PAD does not appear to have a direct relationship to the patient’s current functional, cognitive, mood or behavior status, medical treatment, nurse monitoring or risk of death at the time of assessment, and therefore would not be reported as an Active Diagnosis in M1028. Note that OASIS item M1023 provides space for the listing of up to 5 Other (secondary) diagnoses. If DM, PAD or PVD were considered to be a comorbid condition that is addressed in the plan of care, with the potential to affect the patient’s responsiveness to treatment, then it would be considered an active diagnosis in M1028, even if it ends up not being listed in M1023, due to the limited number of coding spaces available in the OASIS.
[Q&A EDITED 05/22; ADDED 10/16; Previously CMS Qtrly Q&A 10/16 Q9]
Since the February 2026 release: April 2026 CMS Quarterly OASIS Q&As
We are looking for clarification regarding applicable diagnoses that qualify for PVD and PAD to respond appropriately to M1028 - Active Diagnoses - Comorbidities and Co-existing Conditions. Would conditions like Raynaud’s disease and other venous insufficiency diagnoses be reported in M1028?
M1028 - Active Diagnoses - Comorbidities and Co-existing Conditions identifies whether PAD, PVD, and/or Diabetes are present and active. The diseases and conditions in this item require a physician (or nurse practitioner, physician assistant, clinical nurse specialist, or other authorized licensed staff if allowable under state licensure laws) confirmed and documented diagnosis at the time of assessment. "Active diagnoses" are diagnoses that have a direct relationship to the patient’s current functional, cognitive, mood or behavior status; medical treatments; nurse monitoring; or risk of death at the time of assessment. Diseases or conditions that have been resolved are not included for M1028. HHA clinicians and coders must adhere to the ICD-10-CM Official Guidelines for Coding and Reporting and assign codes as provided in the ICD-10-CM List of Codes and Descriptions (current coding manual). The conditions of PVD/PAD and DM can be represented by a variety of ICD-10 CM codes; therefore, CMS does not provide an exhaustive list of diagnoses that would be included in M1028. Utilizing the guidance provided determine if your patient meets the definition of presenting with an “active diagnosis” for any or all of the specific diagnoses included in the item.
Source: CMS OASIS Q&As: Category 4 - OASIS Data Set: Forms and Items (March 2026) and April 2026 CMS Quarterly OASIS Q&As (April 2026), text extracted from the PDF with pdftotext, retrieved 2026-10-09. Works of the US Government are in the public domain.
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