M2020: CMS OASIS Q&As

Yes, this is considered a drug diary or chart. The statement for response 1b - another person develops a drug diary or chart pertains to someone other than the patient developing the aid. Assess whether the patient must use this list to take the medications at the correct times. If they do require the list and also require someone else to create it, then Response 1 is the appropriate choice.

M2020 - Management of Oral Medications is not automatically assigned a specific code just because a patient resides in a facility, such as an assisted living facility (ALF). M2020 should report the patient’s ability to take the correct dose(s) of the correct oral medication(s) at the correct times. The assessing clinician uses clinical judgment to determine the patient’s current ability based on observation and assessment of the complexity of the patient’s overall drug regimen, as well as patient characteristics, including cognitive status, vision, strength, manual dexterity, and general mobility. Assessment of a patient in an ALF includes consideration of whether a patient can get to the location where the medications are routinely stored at the correct times, can recognize the correct medication dose(s), and take their oral medications, recognizing that someone would need to make the medication available to the patient once they are at the location (e.g., nursing office or medication cart). A patient residing in an ALF could be coded with a response 0, 1, 2 or 3 depending on the level and timing of assistance required on the day of assessment to allow the patient to take the correct dose(s) of all oral medications reliably and safely at the correct times. Code 0 - Able to independently take the correct oral medications(s) and proper dosages at the correct times, if at each administration time, the patient can independently get to the location where the medications are routinely stored, confirm the correct dose, and take all oral medications safely. This is true even though a staff member must unlock and make the medication available at each administration time. Apply this same guidance for M2030 - Management of Injectable Medications when access to a patient’s injectable medications is restricted by ALF policies.

No.

M2020 - Management of Oral Medications assesses the patient's ability to prepare and take oral medications reliably and safely. Tasks include the ability to obtain the medication from where it is routinely stored, ability to read the label (correct medication), open the container, select the pill/tablet or milliliters of liquid (correct dosage), and orally ingest at the prescribed time (take). In some cases, the family or caregiver may impose a temporary barrier that limits the patient's ability to access their medications from where they are routinely stored, e.g. a family that relocates the medications out of the reach of visiting children for the child's safety not the patient's. In the situation where the medications are in a home location that the patient would require assistance to access, code based on the patient’s physical and cognitive ability to access the medication from where it is routinely stored, and to take their medications at the right time and in the right dose.

M2020 - Management of Oral Medications is asking if the patient has the ability to prepare and take oral medications reliably and safely - the correct dosage at the correct times. Preparation includes the ability to obtain the medication from where it is routinely stored, the ability to read the label (or otherwise identify the medication correctly, e.g., patients who cannot read and/or write may place a special mark or character on the label to distinguish between medications), open the container, select the pill/tablet or milliliters of liquid, and orally ingest it at the correct times. Some patients may require medications to be dispensed in bottles with easyopen lids, while others may not. Arranging to have medications dispensed in bubble packs is an excellent strategy that may enable a patient to become independent in the management of their oral medications. Because a patient utilizes a special method or mechanism in order to take the correct medication, in the correct dose, at the correct time, does not necessarily make them dependent in the management of their oral medications. All patients are dependent on their pharmacist to dispense their medications in containers appropriate to their needs. Once in the home, if the patient requires someone else to prepare individual doses, or fill a pill box or planner, or create a diary or med list in order to take the correct med in the correct dose at the correct time, the patient would be scored as response 1 indicating they require someone's else's assistance.

If the patient requires another person (e.g., nurse, family member, friend, caregiver) to give them daily reminders AND the patient has taken all of their oral medications on the day of assessment they are considered a response 2. If the patient requires an automated dispensing system with visual or audio reminders, they continue to be scored a response 2 if someone other than the patient must program the device. If the patient successfully and independently programs/manages the device and takes all oral medications appropriately on the day of assessment, the patient would be scored a response 0.

Response 3 - Unable to take medication unless administered by another person, describes a patient who does not have the physical or cognitive ability on the day of assessment to take all their medications at the correct dose every time it is ordered to be administered, and it is not yet clear if new strategies (a drug diary, a med box, etc.) will allow the patient to take medications independently or with reminders. At a subsequent visit the clinician could reassess to determine if the interventions were adequate strategies allowing the patient to take all medications safely, possibly resulting in a more independent code then response 3 at a subsequent assessment timepoint. Some examples of Response 3, (but not a finite list) include:

• •A patient who decided not to take their new medications, because the varying doses worried them, and they were unsure of the instructions. There had not been a medication organizer/box set-up, nor reminders tried. The clinician would select Response 3 if it is unclear if the interventions will be successful.
• •A patient who, upon assessment, was not able to take prescribed medications at the correct time and doses even though reminded.
• •A patient who, on the day of assessment, was prescribed oral medications, but was unable to safely swallow without supervision.

When completing M2020 - Management of Oral Medications, you are reporting the patient's ability to take all oral medications reliably and safely at all times on the day of the assessment. In situations where one or more medications that are currently listed on the Plan of Care are not available to the patient, preventing the patient from being able to demonstrate their ability to manage oral medications, the assessing clinician could code using assessment strategies other than direct observation. The assessing clinician would rely on their assessment of the complexity of the patient’s overall drug regimen, as well as patient characteristics, including cognitive status, vision, strength, manual dexterity, and general mobility, and use clinical judgment to determine the patient’s current ability. In selecting a code, the clinician may use information gathered by report and/or observation, including details about when and how the patient accesses and administers their medications.

In situations where one or more medications that are listed on the Plan of Care are not available to the patient, preventing the patient from being able to demonstrate their ability to manage oral or injectable medications, the assessing clinician could code using assessment strategies other than direct observation. The assessing clinician would rely on their assessment of the complexity of the patient’s overall drug regimen, as well as patient characteristics, including cognitive status, vision, strength, manual dexterity, and general mobility, and use clinical judgment to determine the patient’s current ability. In selecting a code, the clinician may use information gathered by report and/or observation, including details about when and how the patient accesses and administers their medications.

M2020 - Management of Oral Medications reports a patient’s ability on the day of the assessment to take the correct oral medications at all the correct times. This would include the tasks of accessing the medications from the location where they are routinely stored in the home, preparing the medications (including opening containers or mixing oral suspensions), selecting the correct dose and safely swallowing the medications, typically involving having access to a beverage. If someone other than the patient must do some part of the task(s) that are required for the patient to access and/or take the medication at the prescribed times, then the patient would NOT be considered independent (Response 0). If another person’s assistance is required to provide set up in advance of the administration times, and with this level of assistance, the patient is capable of self-administering the correct meds at the correct times and dosages on the day of assessment, then Response 1 would apply. The following are examples of how the need for assistance or an environmental barrier could impact ability: Scenario: Medications are routinely stored in the refrigerator located downstairs. The patient requires someone to assist them at medication administration time to walk to the location where the medications are routinely stored, or someone must retrieve the medications and bring them to the patient; Response 3 would apply. In this situation, just someone preparing the doses in advance did not enable the patient to self-administer their medications. Scenario: The patient requires someone to prepare the medication doses in advance (e.g., visually they can't discern the appropriate dose) and to walk with them at all times to be safe. In advance of the administration time someone prepares the medi-planner and sets it within the patient's reach with the water they will need to take the meds. The appropriate score is 1, as the patient can access the medications from where they are routinely stored and has the water available to swallow the medication safely. If the medications were routinely stored in the kitchen and/or the water was not available for the patient to self-administer and the patient required someone to assist them to the location where the meds were stored and or to water, the appropriate score would be 3. Scenario: Patient does not need doses prepared in advance, but the medications are routinely stored in a location that the patient cannot access due to a physical, sensory, or environmental barrier. The patient is scored 3. During the episode, an environmental modification was made, e.g., changing the medication storage and water supply to a location that the patient can access, the patient could be scored 0 at the next OASIS data collection time point.

No. Medications given per an inhaler or sublingually are not considered when answering M2020 - Management of Oral Medications. When you assess M2020 consider those medications which are administered per the oral (p.o.) route. P.O. medications are swallowed and absorbed through the GI system. Sublingual medications are absorbed through the mucosal membranes under the tongue.

M2020 - Management of Oral Medications reports a patient’s ability on the day of the assessment (24 hours preceding the visit and time spent in home for the visit), to take the correct oral medications at all the correct times. PRN oral medications that are not needed on day of assessment, are not included in M2020. If the patient did not need any PRN medications on the day of the assessment, assess the patient’s ability on all of the medications taken on the day of assessment. In your scenario, we are assuming the two medications listed reflect all of the prescribed and/or over the counter oral medications relevant to the episode and the patient was no longer taking the Tamiflu. If the patient did not need/take the PRN Ativan within the time period under consideration for the discharge assessment, M2020 would be coded NA - No oral medications prescribed.

In the case of an admission to home care following a discharge from an inpatient facility, M2020 - Management of Oral Medications and M2030 - Management of Injectable Medications should be scored based on the orders relevant to medications that will be taken/administered in the home and will not include a reporting of medications that were administered while the patient was an inpatient. Restrictions imposed during a recent hospitalization should not impact the reporting of the patient’s current status. If the patient had been discharged from an inpatient facility on the day of the assessment (24 hours immediately preceding the visit and the time spent in the home), the clinician would gather information by report regarding the patient's cognitive and physical status prior to the assessment and assess the patient's status during the assessment and make a determination regarding the patient's ability to manage all the medications ordered to be administered in the home at all times. At the SOC, the clinician has up to five days after the SOC date to complete the comprehensive assessment, including the patient’s ability to manage medications. The intent of M2020 is to identify the patient’s ability to take all oral medications reliably and safely at all times. If the patient’s ability to manage the home medications varied on the day of the assessment, the clinician would report the patient’s ability to manage the medication for which the most assistance was needed.

M2020 - Management of Oral Medications reports the patient’s ability to prepare and take (ingest) oral medications reliably and safely at the appropriate dosage and times. On the day of assessment, if the clinician discovers the patient has not been able to swallow prescribed oral medications in the past 24 hours, Response 3 - Unable to take medication unless administered by another person should be selected, as it is the best response option available. If it is identified that the route of administration of the medications (which may have originally been prescribed as “oral medications”) had been changed to administration “per tube” due to the patient’s inability to swallow, and this has been the patient’s usual status on the day of assessment, then Response NA - No oral medications prescribed should be selected.

The patient you described would be scored as response 3 – Unable to take medication unless administered by another person because on the day of the assessment, the patient did not possess the ability to take the Prednisone at the correct time and dose and demonstrated that through their report and actions. The pill planner had not enabled them to take the medications as ordered and a reminder could not have enabled the patient to take a medication when they didn’t have any idea what time and dose they needed to take the medications. Rationale: First, note you are to report your patient’s ability on the day of the assessment (24 hours prior to the assessment, and the time spent by the clinician conducting the assessment) and if ability varied, you report what was true regarding the medication that required the most assistance during that time period. This would mean you would not report ability after skilled intervention, as this is not a reflection of what was true in the most dependent medication during the day of assessment. A patient who does not have the requisite knowledge and no existing compensatory mechanisms to take the medication(s) as prescribed would be scored 3 until after they received the required education and demonstrated to the clinician that they were able to take ALL medications at the correct dose and time or until the clinician has introduced an assistive device, such as a pill planner, and the patient has demonstrated success at taking meds as ordered, at all times.

In situations where one or more medications that are listed on the Plan of Care are not available to the patient, preventing the patient from being able to demonstrate their ability to manage oral or injectable medications, the assessing clinician could code using assessment strategies other than direct observation. The assessing clinician would rely on their assessment of the complexity of the patient’s overall drug regimen, as well as patient characteristics, including cognitive status, vision, strength, manual dexterity, and general mobility, and use clinical judgment to determine the patient’s current ability. In selecting a code, the clinician may use information gathered by report and/or observation, including details about when and how the patient accesses and administers their medications.

M2020 - Management of Oral Medications identifies the patient’s ability to take all oral (p.o.) medications reliably and safely on the day of assessment. M2030 - Management of Injectable Medications identifies the patient’s ability to take all injectable medications reliably and safely on the day of assessment. Note that any assistance or transportation required to get the medication(s) into the home is not considered when coding M2020 and M2030. Include assessment of the patient’s ability to obtain medications from where they are routinely stored in the home, the ability to read the labels (or otherwise identify the medications correctly, for example patients unable to read and/or write may place a special mark or character on the label to distinguish between medications), open the containers, select the appropriate dose (pill/tablet, milliliters of liquid, etc.) and orally ingest (or inject) at the correct times. Once the medication(s) is/are in the home, if someone other than the patient must do some part of the task(s) that are required for the patient to access and/or take the medication at the prescribed times, then the assistance required would be considered when determining the code for M2020 and M2030.

In the situation where the medications are locked up in the assisted living facility (ALF) nursing office, code based on the patient’s physical and cognitive ability to access the medication from where it is routinely stored, and to take their medications at the right time and in the right dose. Assess the patient’s ability to access medications based on where the medications are routinely stored. If the routine location has been temporarily modified, continue to code based on an assessment of the patient’s ability to access from the location where the medications are routinely stored.