Author: Leigh Massey, RN, JD, WOCN, CHC, CHPC
Posted: August 23, 2022
CMS introduced OASIS-E changes for Home Health Agencies to meet the requirements of the IMPACT Act and improve interoperability among the post-acute continuum. The Act requires implementation of standardized quality measures and the development and reporting of measures pertaining to resource use, hospitalization, and discharge to the community. These requirements are reflected in the OASIS – E tool as new assessments:
This article will address the Reconciled Medication List. Future articles will address the other IMPACT requirements.
Reconciled Medication List (Section A)
This assessment falls into the quality measure domains for Medication Reconciliation and Transfer of Health Information and Health Preferences When an Individual Transitions; it is also considered in the resource use domain Discharge to Community.
This series of questions is related to how “M0100: Reason For Assessment” is answered. Depending on whether the patient is transferred to an inpatient facility or discharged with formal assistive services or not, the home health agency is responsible to provide a current reconciled medication list to the appropriate subsequent provider or patient. Compliance with this requirement is documented in items A2120 - A2124.
A current reconciled medication list refers to the list of the patient’s current medications at the time of transfer/discharge that was reconciled by the agency prior to the patient’s transfer or discharge. The list should include:
Your agency should be guided by the current standards of care and the Conditions of Participation in determining what should be included in a current reconciled medication list. An updated agency policy for this standard is recommended.
This item relates to § 484.58 Condition of participation: Discharge planning, which provides: (1) The HHA must send all necessary medical information pertaining to the patient's current course of illness and treatment, post-discharge goals of care and treatment preferences to the receiving facility or health care practitioner to ensure the safe and effective transition of care.
Providing a current reconciled medication list at the time of transfer or discharge can improve coordination, quality of care, help subsequent providers reconcile medications and may mitigate adverse outcomes related to medications. Communication of medication information is critical to ensure safe and effective transitions from one health care setting to another. Provision of this information to patient after discharge without formal assistive services also helps empower the patient in managing their own self-care and can prevent rehospitalization. It is important to understand who should receive the current reconciled medication at each time point.
Provision of Reconciled Medication List at Transfer
For transfer to inpatient services, the subsequent provider is identified when the patient has been transferred to any inpatient facility.
Provision of Reconciled Medication List at Discharge
At discharge, however, a subsequent provider is identified when the patient has been discharged with formal assistive services (under the care of another Medicare certified home health agency or home hospice). The OASIS – E Guidance Manual states that while the patient may receive care from other providers after discharge from your agency, such as primary care providers, outpatient providers, and residential treatment centers, these locations are not considered to be a subsequent provider for coding this item. Best practice for continuity of care, however, dictates that if a patient is not discharged with formal assistive services, this information should be given to the patient and their primary care provider of record.
While the discharge and transfer summaries are required to also be sent to the subsequent provider, the OASIS – E only captures whether a reconciled medication record was sent. * It is to be sent in the same period required for the transfer and discharges summaries (§ 484.110 (6) Condition of participation: Clinical records).
The last set of questions, A2122 and A2124 relate to how the current reconciled medication list was transmitted to the provider. Definitions for each route of transmission are outlined in the OASIS – E Guidance Manual.
OASIS – E Guidance Manual, Effective 1/1/2023, Centers for Medicare and Medicaid Services