October 1 update. Our PDGM and ICD-10 tools now use the FY2027 code set: 190 codes added, 30 deleted, and no existing code changed clinical group.

See what changed

OASIS · CMS Q&As

M1800: CMS OASIS Q&As

8 questions CMS has answered, quoted whole from the CMS OASIS Q&As.

CMS OASIS Q&As · March 2026

M1800 on the OASIS item lookup

M1800 Q127.1Category 4b - OASIS Data Items

M1800 - M1870. Are service animals considered a form of assistance?

If required for a patient’s safe function, service animals should be considered an assistive device for purposes of selecting responses to the OASIS items. Service animals should not be equated to human assistance (e.g., “someone must assist…”)

[Q&A EDITED & ITEM NUMBER UPDATED 05/22; ADDED 01/11; Previously CMS OCCB Q&A 10/09 Q27]

M1800 Q127.2Category 4b - OASIS Data Items

M1800, M1830, M2102a, GG0130E. OASIS excludes shampooing of hair from Bathing and Grooming…Is this captured any other place?

Shampooing of the hair is excluded from the M1830 - Bathing and M1800 - Grooming. Shampooing the hair is also excluded from GG0130E - Shower/bathe self. Shampooing may be included as one of the ADLs in M2102a - Types and Sources of Assistance; ADL assistance, as this question is concerned broadly with types of assistance, not just the ones specified in other OASIS items.

[Q&A EDITED 05/22; EDITED 10/18; EDITED & M number updated 06/14; ADDED 01/11; Previously CMS OCCB Q&A 01/10 Q10]

M1800 Q127.3Category 4b - OASIS Data Items

M1800 - M1870. About M1800 - M1870: I don’t understand the difference between “willingness” and “adherence” (which do not impact OASIS scoring) and “cognitive/mental/emotional/behavioral impairment” (which may impact OASIS scoring). For instance, if a person is unwilling to bathe appropriately, resulting in poor hygiene, an offensive odor and increased risk for infection, isn’t the patient suffering from some sort of cognitive, mental, behavioral or emotional problem that would cause this unwillingness and non-adherence? It seems that such unwillingness is a symptom of a deeper psychological problem. Please clarify.

In absence of pathology, patients may make decisions about how and when they perform their activities of daily living that may differ from what the clinician determines to be acceptable. A patient may choose to shave and brush their teeth infrequently because they don’t value doing it at a frequency that the clinician deems as socially appropriate. There are differences in the frequency at which grooming or bathing is performed, or expected to be performed based on age, religion, culture and familial practices, and this is not necessarily indicative of pathology. A patient may demonstrate that they can safely ambulate while using a walker, but then as a matter of choice, decide to walk without it. Another patient may demonstrate that they can safely ambulate while using a walker, but then consistently walk without it, forgetting that they have a walker. For the purposes of OASIS scoring, non-conformity or non-adherence should not automatically be considered indicative of a deeper psychological impairment. The assessing clinician will have to use clinical judgment to determine if the patient’s actions are more likely related to impairment, or to personal choice made in awareness of the potential related risk.

[Q&A EDITED 10/23; EDITED & ITEM NUMBER UPDATED 05/22; EDITED 06/14; ADDED 01/11; Previously CMS OCCB Q&A 07/10 Q13]

M1800 Q127.4Category 4b - OASIS Data Items

M1800 - M1870. When the M item response states "assisted or supervised by another person" is that referring to a single person?

The response related to "assistance of another person" includes those patients needing assistance of one or more person(s) to safely complete included tasks.

[Q&A EDITED AND ITEM NUMBER UPDATED 05/22; ADDED 01/12; Previously CMS OCCB Q&A 07/11 Q11]

M1800 Q127.5Category 4b - OASIS Data Items

M1800 - M1870. My staff are confused about when a patient's ability to access the location and/or implements needed to complete the M function items should be considered when scoring the OASIS. For instance, should I include a patient's ability to get to the tub for M1830 - Bathing, or to get to the kitchen to eat for M1870 - Feeding or Eating?

The OASIS M function items consider the patient’s ability to access the needed items and/or location where the task is performed unless item guidance specifically excludes these from consideration. The M function items where there are exclusions are: M1830, Bathing - The focus is on the patient's ability to access the tub/shower, transfer in and out, and bathe the entire body once the needed items are within reach. The ability to access bathing supplies and prepare the water in the tub/shower are excluded from consideration when assessing the patient's bathing ability. M1845, Toileting Hygiene - The focus is on the patient's ability to access needed supplies and implements and manage hygiene and clothing once at the location where toileting occurs. The ability to access the toilet or bedside commode, transfer on and off the bedpan and to use the urinal are excluded from consideration when assessing the patient's toileting hygiene ability. M1870, Feeding/Eating - The focus is on the patient's ability to eat, chew and swallow once the meal is placed in front of the patient and needed items are within reach. The ability to access the location where the meal is prepared and consumed, and transporting food to the table are excluded from consideration when assessing the patient's feeding/eating ability.

[Q&A EDITED 05/22; EDITED 10/18; ADDED & EDITED 06/14; Previously CMS Qtrly Q&A 04/13 Q7]

M1800 Q129Category 4b - OASIS Data Items

M1800. Must I see the patient comb their hair or brush their teeth in order to respond to this item?

No, an assessment of the patient’s coordination, manual dexterity, upper-extremity range of motion (hand to head, hand to mouth, etc.), and cognitive/emotional status will allow the clinician to evaluate the patient’s ability to perform grooming activities.

[Q&A EDITED 05/22; REVIEWED 09/09]

M1800 Q129.1Category 4b - OASIS Data Items

M1800. Please confirm that the assessment of the patient's ability to perform the grooming tasks identified in M1800 - Grooming also includes getting to where the grooming utensils are stored.

Patient access must be considered when determining grooming ability (e.g., grooming aids, mirror, sink). If there is an environmental barrier preventing safe access or the patient has an impairment that causes them to require someone’s assistance to gain access to needed items or locations, whether the assistance was to take the items to the patient, or to assist the patient to get to the items, Response 1 - Grooming utensils must be placed within reach before able to complete grooming activities would be appropriate, assuming the patient could then groom independently in a majority of the more frequently performed grooming tasks. This item addresses the patient's ability to safely perform grooming given the current physical and mental/emotional/cognitive status, activities permitted and environment. The patient must be viewed from a holistic perspective in assessing ability to perform ADLs. Ability can be temporarily or permanently limited by environmental barriers (e.g., accessing grooming aids, mirror and sink).

[Q&A EDITED 05/22; EDITED 06/14; ADDED 12/12; Previously CMS Qtrly Q&A 10/12 Q6]

M1800 Q129.2Category 4b - OASIS Data Items

M1800. OASIS guidance tells us that the ability to access the location and items needed to complete grooming tasks are considered in M1800 - Grooming, so if patient needs to be assisted to the bathroom for safety, or needed grooming items placed within reach, but then could complete the tasks with no further assistance, they would be scored a response 1. Some clinicians refer to M1800 response 1 for grooming as “set up”. For OASIS scoring, if a patient needs assistance to open and/or set up grooming items (i.e. put toothpaste on toothbrush, opening the top of the toothpaste tube or other items such as items to apply make-up), is this considered providing access to the items and scored as a response 1, or is it considered providing assistance and scored a response 2 as long as the majority of the grooming tasks required this assistance?

Response 1 for M1800 - Grooming relates to patient access of “utensils” needed for grooming (e.g., accessing grooming aids, mirror, sink). Response 1 for M1800 is placing grooming items within reach and is not to be considered the same as the 05 - Setup or clean-up assistance code used for the GG0130 activities which includes assistance a helper provides only prior to or following the activity, but not during the activity. Each OASIS item should be considered individually and coded based on the guidance provided for that item In your scenario, putting toothpaste on the toothbrush and opening the top of the toothpaste goes beyond placing the items within reach and would be considered providing assistance for M1800.

[Q&A ADDED AND EDITED 05/22; Previously CMS Qtrly Q&A 07/19 Q10]

Also mentioned in

Source: CMS OASIS Q&As: Category 4 - OASIS Data Set: Forms and Items (March 2026), text extracted from the PDF with pdftotext, retrieved 2026-10-09. Works of the US Government are in the public domain.

Every CMS OASIS Q&ACategory 4a - General Questions

The monthly home health regs digest

What CMS changed, what's due next, and what to do about it — one email a month, no fluff. Read the first issue