CMS Releases New OASIS Guidance Manual

The OASIS guidance manual set to take effect next year now is available, marking yet another step toward standardized collection of post-acute data and potential changes to the Medicare payment system.

The Centers for Medicare & Medicaid Services (CMS) on June 27 posted the OASIS-C2 Guidance Manual online, after having posted a draft version in late December 2015. OASIS-C2 is scheduled to be implemented on Jan. 1, 2017, and replaces the version of the data set that was created to conform with ICD-10 coding.

Among the major differences in the new guidance manual are several items added in response to the Improving Medicare Post-Acute Care Transformation (IMPACT) Act. Passed in 2014, the law requires standardized data to be submitted by various post-acute providers, including skilled nursing facilities (SNF) and inpatient rehabilitation facilities (IRFs), in addition to home health agencies.


The goal of IMPACT is to get an apples-to-apples comparison of outcomes and costs in various settings, with the ultimate goal of adjusting Medicare reimbursements accordingly.

Appendix G of the new manual summarizes the changes from OASIS-C1/ICD-10 to OASIS-C2, including new items/IMPACT Act items. They include but are not limited to:

– M1028: Active Diagnoses, Comorbidities and Co-existing Conditions


– M1313: Worsening in Pressure Ulcer Stats since SOC/ROC

– M2001: Drug Regimen Review: Did a complete drug regimen review identify potential clinically significant medication issues?

Among other items of note, the new Guidance Manual includes instructions on how agencies can adopt pressure ulcer guidelines from the National Pressure Ulcer Advisory Panel (NPUAP). Agencies may adopt NPUAP guidelines but definitions on staging may not align with OASIS scoring instructions. If so, agencies are instructed to rely on the OASIS instructions, the manual states.

Click here to view the entire OASIS-C2 Guidance Manual.

Written by Tim Mullaney

Photo Credit: “Stacked papers in folder” by Lindsay Holmwood, CC BY 2.0

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