Q: A patient was discharged from the hospital Monday and was scheduled for a Tuesday morning home health agency admission. Monday night he experienced a problem that required a skilled nursing visit from the on-call nurse who was not able to do an initial start of care OASIS assessment at that visit. Is that visit considered a billable visit and the start of care date if the complete OASIS assessment is done by the case manager on Tuesday morning as originally scheduled?
A: This question illustrates a common confusion regarding the “initial assessment visit” a patient receives and the completion of the “comprehensive assessment.” There is a distinction between the two requirements. During a patient’s initial assessment visit, which is by definition the first visit a patient receives, there must be an assessment that determines “immediate care and support needs of the patient; and for Medicare patients…the eligibility for the Medicare home health benefit, including homebound status” (Conditions of Participation, §484.55(a)). Although many agencies require that the comprehensive assessment, which includes OASIS, also be completed during the initial assessment visit, this is not a regulatory mandate. The comprehensive assessment with OASIS 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” (Conditions of Participation, §484.55(b)).
The visit made by the on-call nurse should have included a basic assessment, including determination of eligibility for the Medicare benefit. It would then count as the start of care. The OASIS can be completed during the 5-day timeframe as appropriate. It would be a good idea to teach clinicians the difference between an initial assessment visit and the comprehensive assessment/OASIS. During the first visit, every Medicare patient must receive an initial assessment, including determination of eligibility, even if that visit is made primarily to meet an immediate need, as was the case in this example. This is true even though it may not be possible to complete the OASIS at that time.
February 23rd, 2010 at 11:28 am
With many agencies using LPN staff these days, is it correct that only an RN visit would qualify as a billable visit in this situation?
February 23rd, 2010 at 1:08 pm
The on-call nurse would have to be the RN completing the OASIS assessment and therefore would need to be the RN making at least one additional visit in the 5 day window alloted for completion of the OASIS.