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Q: Must the plan of care include parameters for monitoring patients with chronic conditions?

Homecare Insider Q&A, January 21, 2010

A:    There is no regulatory requirement to document parameters for physician notification on the plan of care.  If there is no requirement, the surveyor cannot cite the agency simply for not listing parameters on the plan of care.  However, the Conditions of Participation, §484.18(b), require clinicians to notify the physician about changes that suggest a need to modify the plan of care.  If the surveyor identifies instances when a clinician has failed to respond to significant findings, he or she can cite the agency.  Example:  The home health aide documented that the patient with a catheter had an elevated temp and her urine had become cloudy and streaked with mucus.  There was no follow-up by the nurse.  These findings indicated a need to modify the plan of care, and the nurse should have contacted the physician.

This is a very timely question, given the recent implementation of OASIS-C.  A new data element, M2250, plan of care synopsis, asks whether the plan of care includes patient-specific parameters for notifying the physician about changes in vital signs or other clinical findings.  The OASIS-C Guidance Manual mentions that parameters may include weight, wound measurements, pain intensity ratings, intake and output measurements, and blood sugar levels.  However, it is important to note that the guidance manual also states that this practice is not required in the Conditions of Participation.  In earlier comments, the Centers for Medicare and Medicaid Services said an agency did not have to change its processes to match the process data elements in OASIS-C.  Remind clinicians of the need to address changes in the patient’s condition.  Emphasize the importance of documenting follow-up actions.  Determine when and how parameters can help an agency better monitor a patient’s condition.  

The audio recording, “OASIS-C and the Agency’s Operations,” examines M2250 and other process data elements, along with the impact on OASIS-C on outcomes and reporting.  Check out this educational program.