Home Health & Hospice Week

In December the Centers for Medicare & Medicaid Services issued Attachment D to the OASIS User's Manual. The attachment contains guidance for filling out the diagnosis coding-related M0 items in OASIS.

But many of the provisions in the guidance left HHAs scratching their heads. Last month CMS issued one correction to the chapter (see Eli's HCW, Vol. XVIII, No. 5, p. 36), and now it has issued more clarifications related to secondary diagnoses.

First error: The first bullet in Section D (3) (b) "incorrectly omits specific secondary diagnosis instruction," CMS says on its home health Web site. The correct wording should be: "Ensure that the secondary diagnosis under consideration includes not only conditions actively addressed in the patient's plan of care but also any comorbidity affecting the patient's responsiveness to treatment and rehabilitative prognosis, even if the condition is not the focus of any home health treatment itself."

Second error: The first sentence in Section D (3) of Attachment D omits the word "or" before the phrase "affect the treatment or care," CMS notes. The correct wording should be: "Secondary diagnoses,or other diagnoses, are defined as all conditions that coexisted with the primary diagnosis at the time the plan of care was established, or which developed subsequently, or affect the treatment or care of the patient."

The corrections come after the National Association for Home Care & Hospice pointed out to CMS that "the majority of home health patients have multiple comorbidities, some of which do not require specific interventions on the part of the home health agency, therefore do not have a place in the plan of care," the trade group says. "However, these comorbidities can have a large impact on resource utilization."

Lingering questions: CMS hasn't addressed all the problems HHAs have with Attachment D, NAHC notes. The trade group hopes the agency will address multiple coding irregularities found in the case scenarios.

HHAs can send questions about Attachment D to AskOasisAttachD@cms.hhs.gov, CMS offers. Note: The corrections and a link to Attachment D are at www.cms.hhs.gov/center/hha.asp.