Pandemic Covid19


It’s tempting to dive into the politics here but nobody ever recovered from anything as a result of winning a political argument. Our immediate needs are to take care of and educate patients, ourselves, our coworkers and sometimes bosses especially if they are not clinical.

The Short List

1. You must protect yourself if you want to protect your patients and those you go home to after work. Nurses in hospitals report seeing people without proper equipment or using. PPE inappropriately headed towards patient rooms Visiting caregivers in home health and hospice have nobody watching them. Have employees demonstrate how to put on PPE so you can be confident they are well protected.

2. Covid19 may not be a one time deal like measles or chicken pox. Those (former) childhood diseases resulted in immunity due to the antibodies formed in response to being ill. Covid19 also spurs the formation is antibodies but they may not protect patients from future infection. This point is important to share with your patients who are recovering or know people promoting this idea. Deliberately catching Covid19 is about as dumb as a bunch of fence posts.

3. Our patients mostly stay at home but their family members may have to work. If this is the case with any of your patients, include the family in your teaching. The working person may choose to stay in their room and, when possible, stake a bathroom that is not shared with other family members. Emphasize to your patient that they are being protected and not ignored.

If your patient has medical appointments scheduled call their practitioner and ask if the appointment can be delayed or if there is something you can do to make it unnecessary for now. Lab and assessment results and medications administered in the a clinic are all within your skill set.

4. If a person is diagnosed with Covid19, there’s a very good chance they were contagious before the onset on symptoms. Likewise, there is a strong possibility that many people infected with Covid19 never have symptoms but have the capability to spread the virus. How fun is that? A stealth attack by a virus residing in an unknown host. Again, this supports the advice to stay at home. Teach patients that they could become infected by having visitors that look perfectly healthy. Set up FaceTime, Zoom, or similar software when smartphones or other technology is available.

Tell your patients on each and every visit to avoid the ER if possible. Give them specific criteria for an ER visit and make sure that the agency and physician numbers are in plain view. If your patient lives alone, make sure they have a panic alert button to summon Emergency Services. Be willing to head to a patient’s house with a syringe full of lasix or call a mobile X-ray company. Not only is the hospital a dangerous place but an ER visit will require use of hospital resources that are in short supply.

5. If you are a hospice nurse, be extremely cautious in. nursing homes. The true number of patients affected by Covid19 in nursing homes may be underreported. In Louisiana, the names of nursing homes that have clusters are no longer being reported.

To be brutally frank, death from Covid19 is worse than death from most other illnesses. The pain management for non-pulmonary patients may not be appropriate for Covid19 patients. It is not okay if a terminal patient contracts the virus. Do not be a vector!

6. There is no known cure or treatment for Covid19. However, we do not prescribe medication. If a patient is prescribed meds that have been re-purposed for Covid19, our job is to teach how to correct administration of meds and possible side effects. Answer questions as directly as possible without coloring them with opinions. If you share a negative opinion of Azithromycin and Plaquenil with patients, their trust in their physician may be damaged and that could cause more harm than the meds.

Covid19 will be an ongoing challenge at least until the end of the year and possibly longer. I expect we will all learn a lot by then.

Meanwhile, we would love to know what you are doing to prevent illness in your patients and staff. Are you able to get appropriate PPE? Are you providing masks for patients? What kind of questions are your patients asking? As an agency, has there been formal education?

We get our best stuff from you so bring it on! You can comment in the comments section or email us directly.

Welcome Back, Mr. SCIC


The SCIC is Back

Nurses who did not enter home health until this decade may be familiar with SCIC’s. Maybe they read about them or they were briefly reviewed in orientation. In the early years of PPS, a SCIC or other follow-up assessment changed the payment of an episode. Then it didn’t. Soon it will again. So the Significant Change in Condition; or other follow-up is a thing and it’s about to be a bigger thing.

The Quarterly OASIS Q and A from Medicare state:

When diagnosis codes change between one 30-day claim and the next, there is no requirement for the HHA to complete an RFA 5- Other follow-up assessment to ensure that diagnosis coding on the claim matches to the OASIS assessment. The CoP 484.55(d) does require an RFA 05 when there has been a major improvement or decline in a patient’s condition that was not envisioned in the original Plan of Care. CMS expects agencies to have and follow agency policies that determine the criteria for when the Other Follow-up assessment is to be completed.

The OASIS User Manual defines ‘RFA-5 other follow-up’ as:

… comprehensive assessment is conducted due to a major decline or improvement in patient’s health status occurring at a time other than during the last five days of the episode. This assessment is done to re-evaluate the patient’s condition, allowing revision to the patient’s care plan as appropriate.

With 30-day claim periods and 60-day OASIS intervals, there may be changes in your patient’s condition causing your patient to need more care that are not reflected in payment. If this occurs during the first claim period, the SCIC assessment is a way to increase payment for the second 30-day claim period. The claim period will only be adjusted if the date of assessment occurs prior to the 30th day.

So, in crafting or revising your SCIC policy, a good place to start would be with the OASIS questions that will affect your outcomes and payment – particularly hospitalizations. Currently, you must collect information on hospitalization risk and it will affect payment. Why not include factors that might increase the patient’s risk for hospitalization?

  • One or more falls
  • Unintentional weight loss of a total of X pounds (contingent upon base weight of patient.)
  • Any hospitalization, ER visit or MD visit that results in a change in orders.
  • Persistent decline in mental, emotional, or behavioral status.
  • Reported or observed history of difficulty complying with any medical instructions (for example, medications, diet, exercise) that is not corrected within two weeks with patient and caregiver education.
  • New medications that require teaching
  • Exhaustion that was not present on admission and does not result from exertion such as family outing or holiday.

All of these criteria have the potential to change the case mix weight. And remember that the Conditions of Participation state that risks for hospitalization should be on the care plan along with interventions on how to mitigate those risks.

Crafting a policy around two mandates already in effect will result in a policy that doesn’t require a lot of extra work to teach or monitor.

Should you have any questions or comments, please email us or leave a comment. If you have a different idea, we are open to hearing it.

PDGM for Nurses


This brief overview is directed specifically to nurses and therapists who will be completing the OASIS assessments that will determine payment. This is not a complete guide to PDGM but it is important for the field clinicians.

You work hard. Get paid.

Happy New Year!


Welcome 2019! If you have performed or reviewed any OASIS assessments since the beginning of the year, you may have been taken aback by the number of changes in the dataset. While its true that more than twice as many questions have been removed than have been added, the questions added have multiple parts and are quite different from the traditional OASIS C questions.

After being immersed in OASIS-D for a couple of weeks, I decided to rest my weary mind today and look at a chart created for a patient who broke her hip. She was admitted to the hospital where she had an ORIF followed by a rehab and then SNF stay. Guess what I found? All the OASIS questions that are new to Home Health Care. This proves to illustrate the ultimate goal of standardization across post acute care providers described in the IMPACT Act. Very simple math will let payor sources know which providers are making patients better. And of course, they already know how much providers are paid. This could be a true advantage to home health. If we can achieve results that are equal to or better than other providers, Medicare will favor home health as providers because we cost less.

The good news is that therapists should be easy to train. In fact, CMS invites a multidisciplinary approach to the OASIS-D assessment and therapists might be the key to getting it right the first time.

The new questions are not difficult but they will require time and thought in order to arrive at the correct answer. There’s a new type of fall to be counted; the intercepted fall where a patient is caught by another before they hit the ground. Witnessed and unwitnessed falls will be documented so like most good agencies, falls will be assessed on each visit. Hopefully, reports will be engineered by software vendors so that you can run reports from your software. OASIS data will tell you how many falls were experienced, what kind of falls they were, and if there was an associated injury. QA will be easy although it is possible that an initial uptick in the number of falls will be the result of constantly assessing. Be sure to count each fall only once.

Mobility has subsections A through S. That’s almost an entire alphabet. The questions are interrelated but each one needs an answer. Only one goal is needed.

The Coders has education available for your agency. Contact us and we will find a day we can spend with your staff educating them about the magical powers of OASIS-D.

To find out if you need additional training, take our OASIS-D Quiz.

And until you are confident that your agency is proficient in the OASIS-D updates, we are always available for OASIS review and/or coding.

Good luck. More later.

Ding!


A client just received their certification report and it was good but not deficiency free as they had been in the past.  The reason?  Although the risk factors for hospitalization were pulled from the OASIS assessment, they were not identified on the Plan of Care as risk factors for hospitalization.  The interventions were similarly not tied to the risk factors even though they did address them.  The DON reported that she talked to a friend at another agency and learned that the other agency had received the very same tag.  Coincidence or survey trend?  Time will tell.  For now, smart agencies will go with ‘survey trend’ as their final answer.

The Condition of Participation is §484.60(a)(2).  It reads:

(2) The individualized plan of care must include the following:

  1. All pertinent diagnoses;
  2. The patient’s mental, psychosocial, and cognitive status;
  3. The types of services, supplies, and equipment required;
  4. The frequency and duration of visits to be made;
  5. Prognosis;
  6. Rehabilitation potential;
  7. Functional limitations;
  8. Activities permitted;
  9. Nutritional requirements;
  10. All medications and treatments;
  11. Safety measures to protect against injury;
  12. A description of the patient’s risk for emergency department visits and hospital re-admission, and all necessary interventions to address the underlying risk factors.
  13. Patient and caregiver education and training to facilitate timely discharge;
  14. Patient-specific interventions and education; measurable outcomes and goals identified by the HHA and the patient;
  15. Information related to any advanced directives; and
  16. Any additional items the HHA or physician may choose to include.

This is a new requirement included in the 2018 Conditions of Participation.  It’s something that (hopefully) has been done by agencies in the past but risk factors haven’t always been labeled.  The requirement is consistent with the CMS goal of avoiding unnecessary admissions.

There are no instructions on how to do this.  Prior to the final regulations, the proposed regs suggested stratifying patients as high, medium or low risk.  That was omitted from the final rule.  From the 2018 CoPs:

While there may be benefits to establishing more inter-HHA consistency in the application of this requirement, we do not believe that those benefits would outweigh the cost of reducing HHA flexibility and innovation to determine the best possible way to achieve the overall goal of reducing unnecessary emergent care visits and hospital admissions.

The OASIS question that examines risk factors for hospitalization is M1033 reads:

(M1033) Risk for Hospitalization: Which of the following signs or symptoms characterize this patient as at risk for hospitalization? (Mark all that apply.)

  •  History of falls (2 or more falls – or any fall with an injury – in the past 12 months)
  •  Unintentional weight loss of a total of 10 pounds or more in the past 12 months
  •  Multiple hospitalizations (2 or more) in the past 6 months
  •  Multiple emergency department visits (2 or more) in the past 6 months
  •  Decline in mental, emotional, or behavioral status in the past 3 months
  • Reported or observed history of difficulty complying with any medical instructions (for example, medications, diet, exercise) in the past 3 months
  •  Currently taking 5 or more medications
  •  Currently reports exhaustion
  •  Other risk(s) not listed in 1–8
  •  None of the above

Additionally, M1036 looks at smoking, obesity, alcohol dependency and drug dependency.  There is a falls risk assessment which may score high in patients who have not fallen in the last 12 months such as those who had a recent hip replacement.  Depression is assessed and is known to impair recovery in most illnesses and conditions but is not included in the question specific for risk factors unless it has an onset within 3 months.

Some of the most dangerous risks to our patients are not captured by OASIS at all.

  • Elderly patients living alone in a rural area
  • Patients unable to afford or prepare food; may have frequent interruptions in utilities due to financial limitations.
  • Transportation or willing caregiver to pick up medications.
  • Functionally illiterate patients

It is possible that drawing in some information from OASIS might meet the condition, but it may not serve the patient.  On the other hand, it is highly unlikely that you would be hit with a survey deficiency if you included risk factors that were based on a full assessment even if they are not included in the OASIS assessment.

You won’t find many interventions to address isolation, depression and lower socioeconomic status in care pathways for other conditions, but they are equally as important for some patients as falls precautions which are ordered for pretty much everyone.  It may cost a little more but in the long run, lower hospitalization rates will correspond with higher margins.

The CoP’s mandate that care plans include patient risks for hospitalizations and Emergency Room visits and corresponding interventions to mitigate the risks.  Since you must do it, make it meaningful.

Contact us if you need help setting up a system for this or if you would have us review your careplans for you.