The January 2022 Quarterly Q&As have been posted by CMS, bringing the industry both new and revised guidance. CMS has confirmed we are still on track to begin OASIS-E January 1, 2023, for all OASIS assessments with a M0090 date of January 1, 2023, or later. The release date of an updated draft set is still to be determined. Further clarification regarding stairs activity was issued, stating other than for a “brief rest,” the stair activity of all the way up or all the way down should be continuous.
For M2420, Discharge Disposition, CMS advised to use response  – Patient discharged from agency, when an OASIS is completed due to a payer change, requiring a new SOC to be performed.
Finally, over the span of 5 questions, it appears that new guidance has been introduced regarding the question of how to respond to M2020/M2030 when a patient cannot demonstrate medication-taking abilities due to a variety of reasons (patient refused or cannot afford to purchase, patient cannot access where the medications are stored, pharmacy problems). Guidance from 2018 had instructed to score these situations as response  – Unable to take. In this latest Q&A though, the instruction for all situations was the same – basically, the “assessing clinician could code using assessment strategies other than direct observation”, using clinical judgment to determine the patient’s current ability. The January Q&As can be accessed here.
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