Home Health & Hospice

Pertinent Diagnoses: Only the Words, not the Criteria, Have Changed

Homecare Insider, February 2, 2009

In late December, the Centers for Medicare & Medicaid Services (CMS) published an updated Attachment D to Chapter 8 of the OASIS Implementation Manual. Of concern to many was the description of a pertinent or secondary diagnosis. Briefly, the revised attachment:
• added new language – “ensure that diagnosis is addressed in the home health plan of care,”
• incorporated one decision point in a flow chart, “the diagnosis must be unresolved,” and
• removed language about a pertinent diagnosis being any comorbidity with impact on rehabilitative prognosis and treatment, “even if not the focus of home health treatment itself.”

Combine the additions with deletion and the result is confusion and concern. Does this revised language mean OASIS can no longer report stable comorbidities such as hypertension or hemiplegia as diagnoses? That would have an impact on care planning and payment.

A closer look reveals there has been no significant change in policy for reporting secondary diagnosis. Undefined terms provide “wiggle room” to support reporting many comorbidities. A chronic condition may be stable but it’s not truly resolved. (Just ask a patient with hypertension what happens if he or she skips one or two pills.) The plan of care must report medications the patient is taking and, therefore, the plan addresses that condition.

But just to resolve any lingering doubts, on December 18, 2008, Beacon Health received a written clarification from the Centers for Medicare and Medicaid Services (CMS). This paragraph is relevant.
“If the specific chronic condition under consideration (e.g., hypertension) has the potential to affect the patient’s specific clinical status or outcome, then the condition should be assigned as a secondary diagnosis.”

As the CMS sorts through the comments, we hope it will revise Attachment D to incorporate the language as it originally appeared in the document in December 2002.
“A pertinent or secondary diagnosis is a condition that coexisted at the time the plan of treatment was established or developed subsequently, which affects treatment or care. It is any condition actively addressed in the plan and also any comorbidity affecting the patient’s rehabilitative potential and responsiveness to treatment, even if the condition is not the focus of home health treatment itself.”

Download Attachment D: “Selection and Assignment of OASIS Diagnoses,” December 2008, at click here. For more explanation, check out the CD, “Diagnosis Coding: 2009 Update.”