Home Health & Hospice

CMS Clarifies Attachment D

Homecare Insider, April 13, 2009

In late December 2008, the Centers for Medicare and Medicaid Services (CMS) published an updated Attachment D to Chapter 8 of the OASIS Implementation Manual.  At that time, Beacon Health was concerned about subtle differences in the description of a secondary diagnosis or comorbidity.  The revised attachment added new language:  “ensure that diagnosis is addressed in the home health plan of care”  and “the diagnosis must be unresolved.”  It 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.”  

These changes created a firestorm of confusion.  Clinicians considered reporting stable conditions on the plan of care but not the OASIS.  They thought that addressing the diagnoses on the plan of care meant listing skilled interventions, even though the condition was stable.  Beacon Health wrote several articles trying to reassure everyone that there were no changes of significance.  Undefined terms provided “wiggle room” to support reporting many comorbidities without having to list skilled interventions.  But the turmoil continued to grow.

It didn’t take CMS long to figure out what had happened.  In February, it posted the language it had originally omitted.
“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.”

Find this language and other Attachment D corrections.

So, in the end, nothing has changed.  Homecare providers should continue to report any diagnosis that can have an impact on treatment and the patient’s prognosis.  

The audio conference on April 16 will revisit Attachment D and discuss in depth some of the coding issues, including completion of M0246, case-mix diagnoses.  For more information, click here.