OASIS · CMS Q&As
M1610: CMS OASIS Q&As
8 questions CMS has answered, quoted whole from the CMS OASIS Q&As and the 2026 quarterlies.
M1610 on the OASIS item lookup
M1610. Is the patient incontinent if she only has stress incontinence when coughing?
Yes, the patient is incontinent if incontinence occurs under any situation(s).
[Q&A REVIEWED 05/22]
M1610. How long would a patient need to be continent of urine in order to qualify as being continent?
Utilize clinical judgment and current clinical guidelines and assessment findings to determine if the cause of the incontinence has been resolved, resulting in a patient no longer being incontinent of urine. There are no specific timeframes that apply to all patients in all situations.
[Q&A ADDED 08/07; Previously CMS OCCB Q&A 05/07 Q23]
M1610. How would M1610 – Urinary Incontinence be answered on ROC for a patient that has a nephrostomy tube that is now capped off? The tube is still present but is not attached to a bag. Is it still considered a urinary catheter?
M1610, Response 2 - Requires a urinary catheter, may be selected if the patient has a catheter or tube that is utilized for urinary drainage, even if drainage is intermittent. If, however, there is a catheter or tube inserted in a urinary diversion and it is capped, with no plan to drain urine, even intermittently, Response 2 should not be selected.
[Q&A EDITED 05/22; ADDED 06/14; Previously CMS Qtrly Q&A 01/13 Q10]
M1610. Urinary Incontinence or Urinary Catheter Presence guidance indicates that if a catheter was inserted and discontinued during the comprehensive assessment we should mark either 0, No incontinence or catheter or 1, Patient is incontinent. Does this mean that intermittent catheterization is no longer considered under Response 2, as essentially this is what you do, insert and d/c during the visit?
No. M1610 – Urinary Incontinence Response 2 - Patient requires a urinary catheter (i.e., external, indwelling, intermittent, suprapubic) remains the appropriate response if a patient requires intermittent catheterization. The current OASIS Guidance Manual Chapter 3 M1610 Coding Tips statement "If a catheter was discontinued during the comprehensive assessment or if a catheter is both inserted and discontinued during the comprehensive assessment, Response 0 or 1 would be appropriate, depending on whether or not the patient is continent" is referring to an indwelling catheter.
[Q&A EDITED 10/23; EDITED 05/22; Edited 06/14; ADDED 01/12; Previously CMS OCCB Q&A 04/11 Q7]
M1610. My patient has an order for a nurse to perform a straight catheterization to obtain a urine specimen for C&S because my patient has symptoms of a UTI. There are no other orders for urinary catheterization. Would this be considered a “condition” requiring catheterization as noted in the item intent for M1610 – Urinary Incontinence? Or does catheterization in M1610 relate to catheterization for urinary drainage only?
A patient requiring a one-time catheterization for the sole purpose of obtaining urine for laboratory testing or other diagnostic procedure would not be considered having a “catheter for urinary drainage” when responding to M1610 Urinary Incontinence or Urinary Catheter Presence. Response 0 or 1 would be appropriate depending on whether or not the patient is continent.
[Q&A EDITED 05/22; ADDED 10/16; Previously CMS Qtrly Q&A 07/15 Q8]
M1610. Do I mark response 1 - Patient is incontinent if my patient voluntarily urinates into a diaper at night only for convenience? She ambulates to the toilet during the day, but states she is tired at night and doesn’t like getting up.
M1610 – Urinary Incontinence reports the presence of urinary incontinence for any reason. Urinary incontinence is defined as involuntary leakage of urine. If the nightly urination is voluntary, meaning the patient has the cognitive and physical ability to urinate in a toilet, etc. but chooses to use a diaper, the patient would not be reported as incontinent in M1610.
[Q&A EDITED 05/22; EDITED 10/18; ADDED 01/11; Previously CMS OCCB Q&A 10/09 Q24]
Since the February 2026 release: April 2026 CMS Quarterly OASIS Q&As and July 2026 CMS Quarterly OASIS Q&As
The guidance for M1610 - Urinary Incontinence or Urinary Catheter Presence includes instructions to code 2 - Patient requires a urinary catheter, when the patient 1) “uses a catheter or tube for drainage”, or 2) “Requires the use of a catheter for urinary drainage…”. The words "presence" and "requires" may contradict each other when a catheter is required, and/or ordered, but not present or used. How would M1610 be coded for cases where, per RN assessment, the patient “requires" a urinary catheter, but there is no order for one? Or a catheter has been ordered, but is not yet present in the home, or is not yet approved by insurance?
Do not select Code 2 - Patient requires a urinary catheter for M1610 - Urinary Incontinence or Urinary Catheter Presence if catheter use has not been initiated (e.g., patient refuses the catheter, a catheter is recommended but not ordered, the catheter supplies are not covered by insurance). Code 0 No incontinence or catheter or code 1 - Patient is incontinent would be appropriate depending on whether or not the patient is continent.
I have a follow-up question related to Question 13 of the April 2026 CMS Quarterly OASIS Q&As. The response provided a clarification that for M1610 - Urinary Incontinence or Urinary Catheter Presence, Code 2 - Patient requires a urinary catheter should not be coded if catheter use has not been initiated. The examples given in the Q&A, (patient refuses the catheter, a catheter is recommended but not ordered, the catheter supplies are not covered by insurance) all represented situations where catheter initiation did not seem like it would be occurring. Our follow up question is how should M1610 be coded if the patient requires the use of the catheter, however the catheter equipment is just not in the home yet, or if at the time of the assessment it is unclear when catheter use will be "initiated". For example, it is identified during a SOC visit that the catheter equipment wasn't ordered, so it is ordered and will arrive in a day or so, or if insurance coverage or denial is not known at the time of the assessment. Does this change how M1610 would be coded?
For M1610 - Urinary Incontinence or Urinary Catheter Presence, report what is true on the day of assessment. For M1610, do not select Code 2 - Patient requires a urinary catheter if catheter use has not been initiated. For M1610, information collected by the assessing clinician during the timeframe for the specified assessment type may be used to inform OASIS coding. If desired, the assessing clinician may consider additional information gathered during the assessment timeframe and determine if any revisions to OASIS items are warranted, consistent with OASIS guidance.
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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