Who Can Complete an OASIS Assessment?

by Keith Grunig

Home Health Nurse gathering OASIS


OASIS- What is OASIS in Home Health

OASIS in home health is really kind of the center of the home health universe.  Most everything revolves around OASIS in one way or another.  If you're dealing with Medicare, Medicaid, Medicare Advantage, or other programs administered by CMS, then you're going to be dealing with OASIS.  It can be really intimidating because there is so much information to gather when a clinician gathers OASIS.  We say gather, because OASIS is really just a bunch of data points that CMS uses to follow trends and track patients, acuity, outcomes, and other key metrics that tell about a patient.  CMS cannot go personally visit each patient.  But correct OASIS can give a lot of important data to Medicare and eventually CMS.  OASIS means Outcome and Assessment Information Set.  What OASIS really does is paint, in code form, a picture of the condition of the patient at the time of the assessment. 

OASIS has had many iterations and changes over time.  CMS uses the data shared to determine a lot of things.  How are patients doing under the care of a home health agency?  Are they getting better?  Are they improving?  OASIS is used to determine reimbursement rates.  OASIS has changed from OASIS originally to OASIS B, OASIS B1, OASIC C, we are now on OASIS D1, with OASIS E set to be rolled a year after the public health emergency ends.  Each OASIS adds or removes questions and data points so that CMS can gather certain pieces of information about the actual condition of the patient.  

OASIS- Who can gather OASIS?

Medicare Conditions of Participattion says:

"Standard: Completion of the comprehensive assessment.

(1) The comprehensive assessment must be completed in a timely manner, consistent with the patient's immediate needs, but no later than 5 calendar days after the start of care.

(2) Except as provided in paragraph (b)(3) of this section, a registered nurse must complete the comprehensive assessment and for Medicare patients, determine eligibility for the Medicare home health benefit, including homebound status.

(3) When physical therapy, speech-language pathology, or occupational therapy is the only service ordered by the physician or allowed practitioner, a physical therapist, speech-language pathologist or occupational therapist may complete the comprehensive assessment, and for Medicare patients, determine eligibility for the Medicare home health benefit, including homebound status. The occupational therapist may complete the comprehensive assessment if the need for occupational therapy establishes program eligibility."


Previously, only skilled nurses, physical therapists, and speech therapists have been able to gather OASIS.  With the directed health measures, occupational therapists can now perform assessments under certain conditions.  Typically, nurses and physical therapists perform OASIS assessments.  There is a 335 page guidance manual from CMS that gives guidance on OASIS rules and regulations.  You can click the link here to read through it.  It can be very complex and that's why many people are confused by it.  Many clinicians don't understand the rules of OASIS, don't understand what the OASIS questions are or aren't asking, and don't understand the impact both statistically and financially having a correct OASIS for each patient can have on a home health agency.  Many of the clinicians are very skilled at what they do.  They are compassionate, capable, understanding, and helpful.  As they gather OASIS, many patients want to appear more healthy than they actually are.  Clinicians want to believe them, so when they ask a question, they take it at face value.  For example, one of the questions on OASIS deals with pain.  Do you have pain?  The patient answers they do not.  The nurse marks no pain on OASIS.  Well, the patient recently fell and fractured their hip and is taking pain medications.  Of course the patient has pain!  Many patients have pain every day because of their age.  Heck, my feet hurt after a long day and can alter how I function.  Someone a lot older than me probably hurts more because of their life experience.  

OASIS Cheat Sheet

Many people ask us for OASIS cheat sheets.  The truth is, there are OASIS assessment helps, but each patient is different with different circumstances, so each patient must be evaluated individually.  Different conditions and disease processes interact differently.  OASIS is not a cookie cutter approach.  Such an approach is a dangerous approach- although many agencies do that.  Many agencies see similar patients and treat them very similarly.  This is a dangerous attitude, because we are providing data to CMS that will be used to determine reimbursement rates, outcomes, star ratings, etc.  If they all look the same, then they'll all be treated the same with the same reimbursement.  The cost of care for each patient is different, therefore each OASIS should be treated differently and individually.

OASIS- Get it right

Home Care Answers specializes in OASIS review and diagnosis coding.  That is all we do every day.  We review documentation, are certified in both coding and OASIS, and use unbiased clinical judgement based on the documentation available to compose a picture, in code form, of the condition of the patient at the time of assessment.  This is exactly what an auditor from CMS would do.  They look at the documentation and determine if the documentation supports the OASIS and diagnosis coding.  We do the same thing.  We want to help agencies get OASIS correct.  When it is correct, then revenue follows, outcomes follow, star ratings follow.  It all revolves around OASIS.  It is good to have a fresh set of eyes review the OASIS so that clinicians can continue to do what they do best- help the patient improve!  We did a previous blog post on what our Reviewers actually do.  You can read that here.  We also did a post about what OASIS questions that PDGM is looking at.  You can read that here

OASIS Data- The Magic Formula

We believe that data drives decisions, but great data drives great decisions.  We provide data back to our clients to show where agencies may be struggling on OASIS.  We provide 4 main reports on OASIS data.  PDGM Questions most often missed.  Overall OASIS questions missed.  5 Star Questions Missed.  And GG questions missed.  These focus on probably the most critical questions as far as the data sent back to CMS.  There are other questions that are very important, but these are the ones CMS is looking at.  Who wouldn't want to know how many times we're suggesting changes to certain OASIS questions?  Would you like to know which clinician is missing it the most?  We provide all of that information in our reviews.  Check it out!  Here is a picture of the reports.  There are some agencies that we are suggesting changes in the 80%+ range and some down in the 30% as this is below.  Each agency is different.  But this data will help agencies get better.  Contact us for a free review!

5 Star Questions

M1850 Transferring7438 / 20744 Changed 35.860%

M1860 Ambulation7196 / 20744 Changed 34.690%

M1400 Dyspneic6050 / 20744 Changed 29.170%

M1830 Bathing5830 / 20744 Changed 28.100%

M1242 Frequency of Pain 4972 / 20744 Changed 23.970%

GG0130C13479 / 20744 Changed 16.770%

GG0130G12826 / 20744 Changed 13.620%

GG0130F12443 / 20744 Changed 11.780%

GG0130H12396 / 20744 Changed 11.550%

GG0170F12290 / 20744 Changed 11.040%

GG0170I12229 / 20744 Changed 10.750%

GG0170E12138 / 20744 Changed 10.310%

GG0170D12046 / 20744 Changed 9.860%

GG0130E11722 / 20744 Changed 8.300%

GG0130A11721 / 20744 Changed 8.300%

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