OASIS-Central

A topic for discussion at Beacon Health’s Mastering Medicare seminars this year was inpatient observation stays. CMS Publication 100-02, Chapter 6, §20.6, defines an observation stay as “a well-defined set of specific, clinically appropriate services, which include ongoing short term treatment, assessment, and reassessment, that are furnished while a decision is being made regarding whether patients will require further treatment as hospital inpatients or if they are able to be discharged from the hospital.” In most cases, the manual notes the beneficiary may not remain in observation status for more than 24 or 48 hours.

In reality, however, things are quite different. The use of observation stays is becoming more extensive and the stays are increasing in length, sometimes up to a week or two. Patients, often coming from the emergency room, are placed in hospital beds and given a wristband, medications, tests, therapies, medical and nursing services, and meals. Some patients don’t learn about the observation stay until they are discharged. Hospital utilization review committees can change an inpatient admission to an observation stay retroactively.

Impact on the transfer assessment

Seminar participants had questions about an observation stay and its impact on completion of the comprehensive assessment with OASIS. The OASIS-C Guidance Manual mandates completion of the transfer assessment when “the patient is admitted to an inpatient facility for 24 hours or longer…. Short-stay observation periods in a hospital, regardless of the duration, do not meet the definition for transfer to an inpatient facility.” There would be no transfer assessment, even if the patient is in observation for a week. When the patient who was not admitted to the hospital returns home, the clinician should determine whether the patient experienced a major deterioration in status. If so, it would be necessary to update the assessment.

Some clinicians have reported that they do not know whether the patient’s stay was an admission or for observation until after the patient returns home. In this case, the clinician has 48 hours from learning about the event to complete the necessary assessments. If the patient was admitted, that would be the transfer and resumption-of-care assessments.

This is an excerpt from the article “Inpatient or Outpatient? The Difference Is Huge” by Diane Omdahl, which originally appeared in the August 2010 edition of Homecare Direction. Learn more about Homecare Direction here!