Your OASIS-D Cliffs Notes

OASIS-D Cliffs Notes

Another summer is coming to an end, and another CMS regulatory change is looming over us. OASIS-D. I’ve spent the last 14 years scrambling to ensure home health and hospice providers have the resources required to navigate regulatory shifts with as little disruption as possible. That’s also my goal for this OASIS-D transition.

With that in mind, here’s my OASIS-D summary. I hope it can serve as your Cliffs Notes. If you find you need additional insights, don’t hesitate to email me directly.

Without further ado…

As we all remember, less than two years ago we implemented the OASIS-C2 data set. It was developed from OASIS-C1/ICD-10 to accommodate new data being collected for the Home Health Quality Reporting Program in support of the IMPACT Act. The OASIS-C2 data item was approved by the Office of Management and Budget (OMB) December 9, 2016 and was implemented January 1, 2017.

Fast forward to fall 2018. Now we need to get our clinicians ready for the new data set, OASIS-D. The OASIS-D set will be effective for all Medicare Homecare patients January 1, 2019. That’s only approximately 20 short weeks from today.

Are you and your team ready?

Many of the changes will require retraining your team to ensure they understand:

  1. Which questions differ and why. The OASIS-D changes will focus on comparing quality indicators — all in an effort to enable CMS to compare locations of services (Homecare, Skilled Nursing Facilities, Etc.) to one another.

  2. How the questions will impact the time and effort required to document a start of care. The changes include more functional items that will require your clinicians to focus and understand the impact. These questions are historically addressed by the evaluating therapist but will now be included in the nursing assessment. There are new fall history questions that have been added to the data set as well as well as modifications to the pressure ulcer questions, which will require more details to the care of these items.

For quick reference, below you’ll find lists of added and removed questions:


  1. M1011-list the diagnoses that actively received treatment in an inpatient facility within the past 14 days

  2. M1017 Diagnoses, Treatment Regimen Change

  3. M1018 Conditions Prior, M1025 Optional Diagnoses

  4. M1034 Overall Status

  5. M1036 Risk Factors,

  6. M1210 Ability to Hear

  7. M1220 Understanding Verbal Content

  8. M1230 Speech and Oral Expression

  9. M1240 Pain Assessment

  10. M1300 Pressure Ulcers Assessment

  11. M1302 Risk of Developing Pressure Ulcers

  12. M1313 Worsening in Pressure Ulcers Status

  13. M1320 Status of Most Problematic Pressure Ulcers

  14. M1350 Skin Lesion or Open Wound

  15. M1410 Respiratory Treatments

  16. M1501 Symptoms in Heart Failure Patients

  17. M1511 Heart Failure Follow-up

  18. M1750 Psychiatric Nursing Services

  19. M1880 Ability to Plan and Prepare Light Meals

  20. M1890 Ability to Use Telephone

  21. M1900 Prior Functioning

  22. M2040 Prior Medication Management

  23. M2110 How Often does the patient receive ADL* or IADL assistance

  24. M2250 Plan of Care Synopsis

  25. M2430 Reason for Hospitalization

  26. M0903 Date of Last Home Visit


  1. GG0100 Prior Functioning

  2. GG0110 Prior Device Use

  3. GG0130 Self-Care

  4. GG0170 Mobility

  5. J1800 Any Falls

  6. J1900 Number of Falls

The most common related question we receive at MHA is, Will the OASIS-D impact the case mix calculations? For the most part, all of the changes to the data set only impact data collection and do not impact the case mix calculations.

Another note: Careful considerations should be made to add validations to Oasis-to-Oasis questions and Oasis to non-Oasis questions. If not addressed timely, many of the additional questions will add duplicative work for the caregivers and could result in inaccurate data collection.

Next steps

First and foremost, make sure your visiting clinicians, quality assurance teams and performance improvement teams thoroughly understated the changes required to ensure compliance. If you find yourself in need of additional assistance we’re here. (After all, your team members already have jobs to do. Who internally has the time to give this shift the time and attention it requires?)

MHA has many trained experts who can guide you through the training process, assist in forms review and help you complete the required validations to ensure you are collecting timely and accurate information.

If you have any additional questions or would like to learn more about how the MHA team can help with this transition, feel free to reach out to me directly at [email protected] I hope to hear from you.

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