OASIS Alert

Then in February, two months after the Attachment D publication, prompted by concerns expressed by the National Association for Home Care & Hospice and many others, CMS released two more changes.

Revision #2: CMS has corrected an error in the first bullet in Section D (3) (b) of Attachment D. "Currently, the first bullet in this section of the document incorrectly omits specific secondary diagnosis instruction," CMS said in a Feb. 12 statement. The correct wording is the following: "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."

Result: This correction clears up confusion over the requirement in Attachment D that said each diagnosis must be addressed in the plan of care, says Lisa Selman-Holman, consultant and principle of Selman-Holman & Associates in Denton, Texas. The old language was in opposition to Chapter 8 and other officialcoding guidance, she explains.

Bottom line: CMS has now acknowledged that other diagnoses should be listed as secondary when they may affect the POC, even if no treatment is needed.

Revision #3: The first sentence in Section D (3) of Attachment D also contains an error, CMS said. Currently, the first sentence in this section of the document omits the word "or" before the phrase "affect the treatment or care." The correct wording is the following: "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."