OASIS-E: M0090

The transition to OASIS-E is upon all Medicare certified home health agencies.  In the January 2022 CMS OASIS Q&As (category 2, Q/A 1), clarification was  the OASIS item, M0090, establishes whether OASIS-D1 or OASIS-E will be the required data set.  As a reminder, the M0090 item is the last date information is used to complete the comprehensive assessment.  Each OASIS RFA (reason for assessment) has a maximum allowance of time to complete the comprehensive assessment.  Home health agencies should also have a policy regarding the agency’s allowed time permitted for assessment completion.  Recertification OASIS (RFA 4) may present the greatest problem for starts of episode of January 2^nd through 5^th.   Due to the 5-day window for assessment completion (days 56-60 of the previous episode), M0090 could conceivably fall during December 2022 (OASIS-D1 data set) or January 2023 (OASIS-E data set). Other RFAs with 2- or 5-day assessment completion allowances may also tricky for agencies.  The bottom line?  Make sure your assessing clinicians and quality assurance staff understand the impact of M0090 on OASIS-E.