OASIS-Central

Q: In reference to M2250, we have always considered our referral to be our verbal order for care, since it contains orders for care from the doctor and we get it prior to providing services. We wouldn’t make a visit without having this referral. This has always been okay with our surveyor. We then send the 485 out for MD signature. Since the CMS expectation hasn’t changed, do you think we are still okay considering that the referral is our verbal order for care? What if intake asked the referral source who is representing the MD if the patient requires special vital sign parameters, diabetic foot care or fall, depression, pain or pressure ulcer prevention intervention? Maybe we don’t have to call the MD after we see the patient?

A: M2250, Plan of Care Synopsis, applies at start of care and resumption of care. It asks whether the physician ordered Plan of Care includes plans/interventions for selected items (e.g., patient-specific parameters, diabetic foot care, fall prevention interventions, etc.). A “yes” response means that the patient condition was discussed and there was agreement as to the plan of care between the home health agency staff and the patient’s physician. If a physician referral for services is received by the agency and completely reflects this agreement, it would be appropriate for the assessing clinician to incorporate these details into the plan of care and select a response of “yes” for the item in M2250. The key here is that the referral contains complete information. If the referral details do not completely specify the plan, then a conversation with the physician would be necessary to establish full agreement of the plan of care. Integrating best practices into the referral intake process so these details are obtained at the time of referral is a good way to assist with completion of this data element.

It’s important to note that any orders, either on the plan of care or verbal orders, that the agency receives on or before the date in M0090, date assessment completed, come into play for this item. Orders obtained after the M0090 date do not apply. The clinician has up to five days to complete the start of care assessment and two days for the resumption of care. M0090 should be the last date that assessment details are obtained, including plan of care and verbal orders.