OASIS · CMS Q&As
M1306: CMS OASIS Q&As
16 questions CMS has answered, quoted whole from the CMS OASIS Q&As and the 2026 quarterlies.
M1306 on the OASIS item lookup
M1306. If you have two Stage 4 pressure ulcers with intact skin in-between them and a tunnel that connects them underneath the wound surface, do you have one pressure ulcer or two?
If a patient develops two pressure ulcers that are separated by intact skin but have a tunnel which connects the two, they remain two pressure ulcers.
[Q&A EDITED 10/16; ADDED 01/12; Previously CMS OCCB Q&A 01/11 Q8]
M1306. We are seeking direction regarding serum filled blisters that are caused by shoes rubbing against the foot. Some of our clinicians consider these “trauma wounds” and others consider them “stage 2 pressure ulcers”. Please advise.
If the cause of a wound is solely a friction force which leads to visible skin impairment, such as the serum filled blister cited in the scenario, it would NOT be categorized as a pressure ulcer.
[Q&A EDITED 05/22; EDITED 10/18; ADDED 10/16; Previously CMS Qtrly Q&A 01/16 Q4]
M1306-M1324. If at the SOC visit, the assessing clinician observes an open ulcer over a bony prominence, with history of pressure and visible bone, can the clinician report this as a Stage 4 pressure ulcer, even if not able to get confirmation of the diagnosis from the physician prior to completing the assessment?
These items are a report of the clinician's integumentary status assessment findings. A pressure ulcer/injury may be reported on OASIS based on visualization of the wound, patient assessment and interview, review of relevant related historical documentation and clinical judgment re: etiology. Although the assessing clinician can report the observed ulcer/injury on the OASIS integumentary status items without physician confirmation, collaboration with the physician is required in order to add a diagnosis and ICD-10-CM code to the OASIS diagnosis items and the patient’s Plan of Care and to receive related orders and/or provide physician ordered care related to the pressure ulcer/injury.
[Q&A EDITED 10/18; EDITED 10/16; EDITED 4/15; ADDED 06/14; Previously CMS Qtrly Q&A 01/14 Q5]
M1306. & M1311. If a patient has an unstageable pressure ulcer due to black stable eschar at SOC and during the episode it peels off and leaves an area of newly epithelialized tissue, how should this be staged at Discharge on M1311 – Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage?
Once the full thickness pressure ulcer is completely covered with new epithelial tissue, the wound is considered healed and no longer reportable as a pressure ulcer on the OASIS.
[Q&A EDITED 05/22; EDITED 10/16; Previously CMS Qtrly Q&A 10/16 Q14; ADDED 04/15; Previously CMS Qtrly Q&A 10/14 Q6]
M1306 - M1324. If a Stage 3 pressure ulcer is closed with a muscle flap, what is recorded? What if the muscle flap begins to break down due to pressure?
If a pressure ulcer is closed with a muscle flap (defined as full thickness skin and subcutaneous tissue partially attached to the body by a narrow strip of tissue so that it retains its blood supply), the new tissue completely replaces the pressure ulcer. In this scenario, the pressure ulcer "goes away" and is replaced by a surgical wound. If the muscle flap healed completely, but then began to break down due to pressure, it would be considered a new pressure ulcer. If the flap had never healed completely, it would be considered a non-healing surgical wound.
[Q&A EDITED 10/16; EDITED 06/14]
M1306 - M1324. I have a question about the current guidance that states: “If a pressure ulcer/injury is surgically closed with a flap or graft, it should be considered a surgical wound and not a pressure ulcer/injury. If the flap or graft fails, it should still be considered a surgical wound until healed”. Is this in reference to ANY point in time that the flap/graft fails? For example, if the area of flap/graft heals and has been 100% re-epithelized for greater than 30 days and a patient subsequently develops a wound at the site of the original flap/graft, would it be considered failed surgical site or would it be considered a pressure ulcer/injury?
If a pressure ulcer/injury was surgically closed with a skin graft or flap, the surgical wound healed, and another pressure ulcer/injury forms in the same anatomical location due to pressure, then this would be considered a pressure ulcer/injury. Note it should be staged at the highest stage the pressure ulcer/injury was prior to closure, unless currently presenting at a higher stage or unstageable.
[Q&A EDITED 02/26; ADDED 05/22; Previously CMS Qtrly Q&A 10/21 Q4]
M1306 & M1340. Would a stage 3 pressure ulcer covered with a pig bladder (skin substitute) be considered a skin graft and therefore a surgical wound? Or would it be considered a pressure ulcer that was unstageable? Or something else?
For OASIS coding purposes, when a pressure ulcer is treated surgically with any kind of graft or flap, it is no longer considered a pressure ulcer and is considered a surgical wound until approximately 30 days after re-epithelialization. In your example, as this ulcer was surgically closed with a skin substitute, the wound should be reported as a surgical wound until the graft is completely healed and no longer reportable. If the flap or graft fails, it should continue to be considered a surgical wound until approximately 30 days after re-epithelialization.
[Q&A EDITED 02/26; ADDED 05/22; Previously CMS Qtrly Q&A 07/18 Q6]
M1306 - M1324. If the patient had a pressure ulcer and the post-op surgical report states it was surgically excised and closed without placement of a muscle flap, do we still have a Stage 4 pressure ulcer-the original etiology or did this become a surgical incision?
If all the tissue damaged by pressure is removed surgically, e.g., amputation or surgical excision, there is no longer a pressure ulcer. It becomes a surgical wound until healed.
[Q&A EDITED 10/16; ADDED & EDITED 06/14; Previously CMS Qtrly Q&A 07/13 Q8]
M1306-M1324. If a single pressure ulcer has partially granulated to the surface, leaving the ulcer open in more than one area, how many pressure ulcers are present?
Only one pressure ulcer is present.
[Q&A EDITED 09/09]
M1306-M1324. Can a previously observable Stage 4 pressure ulcer that is now covered with slough or eschar be categorized as Stage 4?
No. In order to stage the pressure ulcer as a Stage 4, bone, muscle, tendon, or joint capsule (Stage 4 structures) must be visible or directly palpable. A pressure ulcer that has some degree of necrotic tissue (eschar or slough) present that the clinician believes may be obscuring the visualization of the wound bed such that the level of tissue damage cannot be assessed, should be reported as unstageable due to slough and/or eschar, even if it was previously numerically stageable.
[Q&A EDITED 10/18; EDITED 10/16; EDITED 06/14; ADDED 06/05]
M1306-M1324. Guidance states that the response to M1311 - Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage cannot be updated when the pressure ulcer that is unstageable at SOC/ROC becomes stageable during the assessment timeframe. Does this guidance also apply to M1324 – Stage of Most Problematic Unhealed Ulcer/Injury that is Stageable?
The first clinical skin assessment is the assessment used to complete the OASIS.This is to ensure consistency of data collection across all post-acute care (PAC) providers. The guidance to assess and report the pressure ulcer stage and status as close to SOC/ROC as possible applies to all OASIS pressure ulcer items.
[Q&A ADDED 05/22; Previously CMS Qtrly Q&A 1/19 Q3]
M1306-M1324. Would a Kennedy Ulcer be considered a pressure ulcer for the purposes of coding the pressure ulcer items on the OASIS?
If an ulcer/injury arises from a combination of factors that are primarily caused by pressure, then the ulcer/injury should be included in pressure ulcer items as a pressure ulcer/injury. End of life ulcers (also known as Kennedy ulcers or terminal ulcers) result from organ failure and are not considered pressure ulcers and therefore not reported on the OASIS pressure ulcer items.
[Q&A ADDED 11/24; Previously CMS Qtrly Q&A 07/24 Q3]
M1306, M1311, M1322 & M1324. How are mucosal membrane pressure ulcers reported in the OASIS data set?
OASIS data set integumentary items only include wounds and lesions to the integumentary system and do not include mucosal membrane wounds or lesions. Pressure ulcers occurring to mucosal membranes would be reported in the comprehensive assessment and clinical documentation but not in any of the OASIS integumentary items.
[Q&A EDITED 05/22; EDITED 10/18; EDITED 10/16; EDITED 06/14; ADDED 12/12; Previously CMS Qtrly Q&A 04/12 Q14]
M1306 - M1332. Are diabetic foot ulcers classified as pressure ulcers or stasis ulcers?
A patient with diabetes mellitus (DM) can have a pressure, venous, arterial, or diabetic neuropathic ulcer. The primary etiology should be considered when reporting whether a patient with DM has an ulcer/injury that is caused by pressure or other factors. Once etiology is determined, the ulcer would be reported in the appropriate OASIS item(s), if applicable. If, for example, a patient with DM has a heel ulcer/injury from pressure, the etiology of the ulcer would be considered pressure, not a diabetic or stasis ulcer, and would therefore be reported in the OASIS pressure ulcer items. The key to coding pressure ulcers is to determine if the primary etiology of the ulcer is pressure. The OASIS includes specific items to capture pressure ulcers, stasis ulcers or surgical wounds. Not all types of wounds will be captured in these items.
[Q&A ADDED 05/22; Previously CMS Qtrly Q&A 10/18 Q4]
M1306-M1324, M1340. If a Pressure Ulcer is replaced with a muscle flap, and before the muscle flap suture line healed completely, pressure caused new break down within the flap area (not along the suture line). Is this considered a non-healing surgical wound? Or a new Pressure ulcer?
If a pressure ulcer is closed with a muscle flap, and before the muscle flap suture line heals completely, pressure causes new breakdown within the flap area (not along the suture line), this would be considered a new pressure ulcer, and until the muscle flap suture site is completely epithelialized for approximately 30 days, the flap site would remain a surgical wound. In this scenario, the patient would have both a new pressure ulcer and a surgical wound simultaneously.
[Q&A ADDED 04/15; Previously CMS Qtrly Q&A 10/14 Q5]
Since the February 2026 release: April 2026 CMS Quarterly OASIS Q&As
If a pressure ulcer is treated with a skin substitute graft that is not surgically applied would the wound still be considered a pressure ulcer or is it considered a surgical wound for the purposes of coding the OASIS?
If the pressure ulcer is treated surgically to apply the graft, the wound is considered a surgical wound and no longer a pressure ulcer. If a "non-surgical" skin grafting approach is used (e.g., epidermal grafting with suction-harvested micrograft, versus the traditional split-thickness or fullthickness surgical graft), then the wound continues to be captured as a pressure ulcer, and not a surgical wound, when coding the OASIS wound items.
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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