OASIS · CMS Q&As
M1311: CMS OASIS Q&As
8 questions CMS has answered, quoted whole from the CMS OASIS Q&As and the 2026 quarterlies.
M1311 on the OASIS item lookup
M1311. Is a pressure ulcer automatically a Stage 4 if osteomyelitis is present, despite what type of breakdown there might be (for example only superficial skin loss)?
The presence of osteomyelitis is not a characteristic used to stage a pressure ulcer/injury and does not automatically result in a Stage 4 ulcer. The pressure ulcer/injury stage should correspond to the clinician’s visual assessment or ability to directly palpate on the day of assessment. The definitions for staging the pressure ulcer are available in Chapter 3 of the OASIS Guidance Manual.
[Q&A EDITED 10/18; ADDED 10/16; Previously CMS Qtrly Q&A 01/16 Q5]
M1311. Upon admission, our patient had two distinct pressure ulcers (one Stage 2 and one Stage 3) in close proximity. Over the course of the episode the ulcers deteriorated and at discharge no longer had any separating tissue. How would this be reported on M1311 - Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage at SOC and at discharge?
Assuming the patient had no other pressure ulcers, on the SOC assessment, M1311A1, Number of Stage 2 pressure ulcers, would be coded “1”. M1311B1, Number of Stage 3 pressure ulcers, would be coded as “1”. In the scenario you describe, at discharge the surface areas of the pressure ulcers extended to the point that the assessing clinician could no longer differentiate one pressure ulcer from the other. In this case, the patient would be considered to have one pressure ulcer. If at discharge, the pressure ulcer was stageable and had not progressed in anatomic depth, the patient would have one Stage 3 pressure ulcer. On the discharge assessment, M1311B1, Number of Stage 3 pressure ulcers, would be coded “1”. M1311B2, Number of these Stage 3 pressure ulcers that were present at the most recent SOC/ROC would be coded “1”. If there had been an increase in numerical stage and the pressure ulcer was a Stage 4 at discharge, M1311C1, Number of Stage 4 pressure ulcers, would be coded “1”. M1311C2, Number of these Stage 4 pressure ulcers that were present at the most recent SOC/ROC would be coded “0”. If the pressure ulcer was unstageable due to slough or eschar at discharge, M1311E1, Number of unstageable pressure ulcers due to coverage of wound bed by slough and/or eschar, would be coded “1”. M1311E2, Number of these unstageable pressure ulcers that were present at the most recent SOC/ROC, would be coded “0”.
[Q&A EDITED 10/18; EDITED 10/16; ADDED 04/15; Previously CMS Qtrly Q&A 04/15 Q2]
M1311. Our patient has a Stage 3 pressure ulcer that we have been treating during the episode. At the reassessment, it is covered with a scab. I know a pressure ulcer is unstageable if it has a non-removable dressing or is completely covered with eschar or slough, but I do not know how a scab would affect the staging for M1311 Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage.
A pressure ulcer that was staged and now has a scab indicates it is healing therefore, staging does not change. In this scenario, it is a healing Stage 3. Scabs and eschar are different. A scab is made up of dried blood cells and serum, sits on the top of the skin, and forms over exposed wounds such as wounds with granulating surfaces (like pressure ulcers, lacerations, evulsions, etc.).
[Q&A ADDED 05/22; Previously CMS Qtrly Q&A 10/18 Q5]
M1311. We had a patient that was admitted with bilateral heel Deep Tissue Injuries (DTIs) coded at SOC as two unstageable - Deep Tissue Injuries. At discharge, the DTIs have some dark eschar tissue on both heels. Should these be considered as present at the most recent SOC/ROC?
For each pressure ulcer/injury observed at discharge, consider current and historical levels of tissue involvement. We would like to clarify that discharge coding for the scenario described is dependent upon the clinical progression of the wound during the episode. If the patient is admitted with two unstageable Deep Tissue Injuries that do not evolve during the home health episode to be numerically staged and are unstageable due to eschar at the time of discharge, then on the discharge assessment M1311E1 - Number of unstageable pressure ulcers due to coverage of wound bed by slough and/or eschar = 2 and M1311E2, Number of these unstageable pressure ulcers that were present at most recent SOC/ROC = 2. M1311F1 - Number of unstageable pressure injuries presenting as deep tissue injuries = 0. However, any pressure ulcer/injury that is observed to be unstageable due to slough and/or eschar at the time of discharge but was previously numerically stageable during the home health quality episode, is considered new, and not coded as present at the most recent SOC/ROC.
[Q&A ADDED 05/22; Previously CMS Qtrly Q&A 10/19 Q23]
M1311. I am looking for clarification in regard to coding of a wound. A patient is admitted with a Deep Tissue Injury (DTI) at SOC/ROC, during the stay the DTI opens, and at discharge presents as two distinct openings with each appearing as a stage 3 pressure ulcer. For the discharge OASIS, should the wound be coded as one DTI “present at the most recent SOC/ROC” or as two stage 3 pressure ulcers - also “present at the most recent SOC/ROC”?
If at discharge you have two stage 3 pressure ulcers, then M1311B1 - Number of Stage 3 pressure ulcers = 2. Assuming no other pressure ulcers/injuries are present M1311F1 Number of unstageable pressure injuries presenting as deep tissue injury = 0. If both stage 3 pressure ulcers present at discharge evolved from the DTI that was present at SOC/ROC, they would both be considered “present at the most recent SOC/ROC” and M1311B2 - Number of these Stage 3 pressure ulcers that were present at most recent SOC/ROC = 2. This is because they were both numerically staged as a stage 3 when first numerically stageable.
[Q&A ADDED 05/22; Previously CMS Qtrly Q&A 07/21 Q5]
M1311. Please provide guidance on how to stage a pressure ulcer on the OASIS when the deepest anatomic soft tissue damage is unknown? We have a newly admitted patient who has had a pressure ulcer for over a year, but there is no documentation available to indicate the highest stage of the ulcer.
For M1311 – Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage, code based on the findings from the first skin assessment that is conducted on or after and as close to the actual time of the SOC/ROC as possible. Do not reverse stage. Consider current and historical levels of tissue involvement. If the pressure ulcer/injury was previously classified at a higher numerical stage than what is observed now, as long as it remains stageable, it should continue to be classified at the higher numerical stage until healed. If historical information is not available to inform the assessment of whether the ulcer/injury was previously classified at a higher numerical stage than what it is observed as now, code based on the current observation of the wound.
[Q&A ADDED & EDITED 11/24; Previously CMS Qtrly Q&A 07/24 Q3]
Since the February 2026 release: April 2026 CMS Quarterly OASIS Q&As and July 2026 CMS Quarterly OASIS Q&As
With the expanded one clinician convention, would it be appropriate if a second clinician performs a remote skin assessment, either by video monitor or by reviewing photographs taken by the assessing clinician during the first skin assessment in order to stage pressure ulcers and code M1311 - Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage?
For M1311 - Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage, code based on the findings from the first skin assessment that is conducted on or after and as close to the actual time of the SOC/ROC as possible. While collaborative feedback from clinical specialists conducting remote review of wound photographs acquired during the “first skin assessment” can contribute to the information the assessing clinician may consider as part of the “first skin assessment,” such remote evaluation would not completely replace the required in-person full-body skin assessment, including direct observation/examination, as applicable.
A pressure ulcer that was present at SOC healed during the quality episode. Prior to the end of the quality episode, the pressure ulcer reopened to the same stage in the same location, and remained open at that stage at discharge. Would this pressure ulcer be considered as “present at the most recent SOC/ROC” when coding M1311 - Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage at discharge?
For M1311 - Current Number of Unhealed Pressure Ulcers/Injuries at Each Stage, if a patient has a pressure ulcer/injury that was documented on SOC/ROC then closes (i.e., heals) during the quality episode and opens again during the quality episode and remains open at discharge, the pressure ulcer/injury should not be coded as “present at the most recent SOC/ROC” when completing the Discharge assessment. This is true even if the pressure ulcer is at the same stage at both SOC/ROC and Discharge. Please note that this response supersedes the guidance found in the OASIS-E2 Guidance Manual, Chapter 3, Section M: Skin Conditions. At times CMS provides new or refined instruction that supersedes previously published guidance. In such cases use the most recent guidance.
Also mentioned in
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) and July 2026 CMS Quarterly OASIS Q&As (July 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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