What do you do when the Recertification OASIS (RFA4) is not done in the five-day window? It does not matter why the Recertification OASIS is missed. It could be because the clinician miss counted and did it early, or totally missed and did not do it before the end of the episode. Maybe the patient refused the visit. According to the OASIS Questions and Answers revised January 2012 you do the OASIS as soon as the error is discovered. You do not discharge and readmit the patient. There are a number of questions that address this issue.
Q10 refers to the situation where the patient refuses a visit between days 56 and 60. In the answer they say if it is impossible to do the follow-up assessment (recertification OASIS) during the five-day window it should be completed as soon after this period as possible. The concern expressed in the answer is that even though it is not explicitly spelled out in the CoP, because the orders for the next episode are expected to be based on the comprehensive assessment, not doing it during the last five days of the previous episode it raises concerns and the HHA should be aware of the legal and payment issues involved.
Q11 looks at what happens if the clinician misses the window between 56 and 60 days but continues providing skilled services. The answer is not to discharge the patient but to send the clinician as soon as the error is identified. M090 should be the date the assessment was actually completed and you should document the circumstances of the late assessment in the clinical record. A warning will pop up for the non-compliance of the M090 date but it will not prevent transmission of the OASIS. For the Medicare PPS patient payment implications may arise and should be discussed with the Agency’s Medicare Administrative Coordinator (MAC).
Q11.1 Asks about the situation where a clinician misses the 5 day window and the patient is ready for discharge on the first visit of the new episode. In this case the answer is you have to do both a recertification OASIS and a discharge OASIS. The answer explains the discharge OASIS is the endpoint for capturing quality data for the quality episode. The follow-up OASIS used for recertification is not used to capture this data.
Q11.2 Asks what to do if you complete the recertification assessment early, on day 54 instead of in the 5 day window of day 56 through 60. The answer for the Medicare PPS patient is again do not discharge the patient. Do not use the OASIS done early either. The answer is to do the recertification assessment as soon as the you realize you missed the 5 day time frame.
Of course every effort needs to be made to avoid missing the 5 day window. And any payment issues that arise need to be discussed with the MAC. If your agency has a trend of being out of compliance with the data collection time frames you need to develop processes that track recertifications and insure the OASIS is completed in compliance.