CMS Releases Home Health OASIS July 2018 Quarterly Questions and Answers

The release of the Home Health OASIS July 2018 Quarterly Q&As brings promise that CMS is back on track to continue quarterly updates that address agency OASIS questions. Nine questions were answered that included more information on the expansion of the one clinician convention and M2102f Supervision and Safety.

Perhaps, one of the most complex responses was the insight provided on “what is” and “what is not” a surgical wound in the context of PleurX catheters. While CMS responded that the type of catheter is not a factor, we are left with more questions than answers from their reply. CMS states, “A surgical procedure that creates a wound that is not an ’ostomy‘, and that has a drain (for example a PleurX catheter, a Jackson-Pratt drain, etc.) would be considered a surgical wound.” Unfortunately, CMS did not give us their definition of ‘ostomy’ and depending on the medical dictionary referenced, the descriptions contradict the information we already have.

A quick look-up in an online free medical dictionary defines an ostomy as an opening in the body to discharge body wastes. This is a broad definition that raises too many questions—Wouldn’t chest tube/thoracostomy drainage be considered body waste? If not, what about abdominal ascites? And, what about all those other ‘—ostomy’ words like tracheostomy? Is it only body waste if it comes from the bladder or intestine? Of course, this returns full circle to the concept of thoracostomy drainage as body waste.

It does not get any easier when using Stedman’s Medical Dictionary. This reference used by health professionals defines ostomy as a surgical procedure that creates an opening between a hollow viscus (internal organ) and the external skin. A thoracostomy is placed in the lung’s pleural cavity—not within the lung itself which would technically meet the definition as a surgical wound. However, CMS has specifically stated a thoracostomy is not a surgical wound. In contrast, a paracentesis with a drain in the abdominal cavity is a surgical wound.

How should the home health clinician approach M1340 to determine if the patient has a surgical wound for these types of wounds? Listed below are tips for accuracy:

1. Know wound types that CMS has specifically referenced as surgical wounds and those listed as not surgical wounds. For example, wounds ending in –ostomy are not surgical wounds; paracentesis with a drain is a surgical wound.
2. Be familiar with medical terminology—a ‘biliary tube’ is a cholecystostomy.
3. For wounds not referenced by CMS, follow the drain! Where is the tip located? Is it within an internal organ or body cavity? Decide as an agency what ostomy definition will be followed.
4. Keep a list—”what is” and “what is not” to be used as a quick reference for clinicians.
5. Be consistent throughout the agency.

In circumstances without definitive answers, CMS has directed agencies to consider all available guidance and rely on clinical judgment to determine the correct responses for OASIS. This seems to be one of those situations.