The Danger of the Dash: Facts to Know Regarding Discharge OASIS

Discharging a patient from home health services isn’t just a final step—it’s a crucial component of quality care and compliance. Whether planned or unplanned, discharge requires a timely and accurate OASIS assessment to ensure the patient’s safe transition and protect your agency from financial penalties. But completing the Discharge (DC) OASIS can be challenging, especially when the discharge is unexpected or documentation is lacking. In this blog, learn the latest CMS guidance, explore how to handle difficult scenarios, and navigate the “danger of the dash”—the costly consequences of incomplete data.

First, discharge from agency services requires a visit to complete the assessment. A Discharge (DC) OASIS is required within 2 days of discharge. Agency policy may dictate the date of discharge, e.g., date of the last visit or 2 days after last visit in the case of a required notice of discharge to the patient or request for discharge.

It is always in an agency’s best interest to perform discharge planning and to complete the DC assessment in person. An accurate discharge OASIS assessment and a timely discharge are essential to keeping that patient safe at home. An effective discharge is even more important with the Discharged to Community—Post Acute Care Value-Based Purchasing (VBP) claims-based outcome.

In the case of an unplanned discharge, CMS still requires the DC OASIS to be based on an assessment. No OASIS guidance allows for a “non-visit” discharge OASIS assessment. Different agencies may call these “assessments” “non-billable” “desk” or “back office” discharges. These types of discharges should never be a routine happening. The DC OASIS requires an in-person patient encounter and assessment. OASIS E1 Q and A Cat2-Q15.3.9

Unplanned or Unexpected Discharge

Guidance allows for the OASIS to be completed by the last qualified clinician who last saw the patient in the situation of an unplanned or unexpected discharge. The OASIS must be completed by the last qualified clinician based on their findings in their last visit. These findings may be supplemented by information documented by other agency staff in visits occurring in the last 5 days that the patient received visits prior to the unexpected discharge. Last 5 days means the date of the last patient visit plus the four preceding days. Some OASIS items allow for a dash and some OASIS items do not. CMS expects the dash to be a rare occurrence so agencies should be aware of the negative attention and negative outcomes unplanned or unexpected discharges may garner, what I call the “danger of the dash.”

Several circumstances may result in the absence or unavailability of the last qualified clinician (maternity leave, termination, etc.). CMS recommends the following in this order:

1. Send another qualified clinician to complete the discharge visit. This should be the agency’s first choice, but of course, it is not always possible. The patient may not be cooperative or has disappeared.
2. If it is not possible for a qualified clinician to visit the patient, look back at the notes and find another qualified clinician who visited the patient to complete the DC OASIS based on their last visit. That assessing clinician can supplement their documentation with information documented by other agency staff in visits occurring in the last 5 days that the patient received visits prior to the unexpected discharge.
3. It may not be possible to complete a DC OASIS assessment. It is not appropriate for a supervisor, or other agency personnel who has never visited the patient to complete a DC OASIS using notes from other agency personnel. What is required when an assessment cannot be completed varies by software, but if there are too many instances of non-completion of an OASIS, CMS can reduce your payment by 2% for non-submission. There is a chance of survey deficiency as well.

OASIS Item Completion

There are many questions regarding how to respond to the OASIS items in the case of an unexpected discharge. To be compliant, the person completing the OASIS must have visited the patient. If the responses are based on the last qualified clinician’s visit, the following recommendations are made based on OASIS-E1 guidance and clinical judgment. Agency personnel are encouraged to make their decisions based on the official guidance and their own clinical judgment.

A1250—Transportation: The last qualified clinician to have visited the patient may find it easy to answer this one. The timeframe of the last 6 months to a year allows for the clinician to respond to this item based on information obtained in previous visits or medical record documentation. Answer accordingly. For example, the patient had a ride to the last doctor appointment or transportation had been arranged for ongoing dialysis.

B1300—Health Literacy: The question in this item must be asked of the patient and no one else. The clinician cannot make assumptions. If the patient cannot be asked, the best response may be ‘7 Patient declines to respond.’

C0100-C0500—BIMS: C0100 can be answered based on information documented in the last visits. The BIMS (Brief Interview for Mental Status) item requires patient performance. Was there a BIMS used with the patient at the last visit? A dash indicates no information. Unless you can get the patient to respond to the screening, you will need to respond with dashes. C0500 will be scored with a dash.

C1310—CAM: This item requires observation of the patient. It is not an interview item. Unless there is enough relevant information in the documentation from the last visits, this entire item will be dashed.

D0150-D0160—Patient Mood Interview: The PHQ2-9 requires interview of the patient. If a patient interview is not possible, then dashes are appropriate in column 1. A dash is never appropriate in column 2. If the interview is not conducted, score D0160 as 99. A dash is not appropriate in D0160.

D0700—Social Isolation: The question in this item must be asked of the patient and no one else. The clinician cannot make assumptions. If the patient cannot be asked, the best response may be ‘7 Patient declines to respond.’

J0510-J0530—Pain Interview: Keep in mind that the patient should have been asked these questions in the last 5 days in the situation of an unexpected discharge. Any pain assessments should include the frequency of pain interference with activity. If unable to ascertain the correct responses, ‘8-Unable to answer’ is the only valid choice as a dash is not appropriate.

K0520—Nutritional Approaches: Respond to column 2 based on orders present on the date of discharge. Respond to column 1 by counting back 7 days, with the date of discharge counting as day 1.

N0415 High Risk Drug Classes: A drug regimen review is required at discharge by the CoPs. A look back to SOC or latest ROC is also required by M2003/M2005. M2003 and M2005 do not include dash options. An updated medication list is required to complete any of these items. Review the medical record for patient-specific indications for each medication.

O0110—Special Treatments, Procedures, Programs: Review the patient’s clinical record and consult with the patient, family, caregiver(s) and/or staff to determine whether or not any of the treatments, procedures, or programs apply during the time period under consideration for the DC assessment. The time period under consideration for the DC is the two-day period prior to the discharge date. If no information is available, dash the items.

GG items—Self-Care and Mobility: Collaboration is allowed when responding to these items. Information can be gathered from agency personnel who have visited the patient in the four days prior to the last visit. Those that cannot be answered should be dashed. CMS will impute responses for the scoring of the Discharge Function outcome.

Conclusion

The DC OASIS assessment is a critical component of patient care and compliance with CMS guidelines. The “danger of the dash” highlights the importance of accurate and complete assessments, as dashes indicate missing information and potentially impact patient outcomes and agency performance. Ensuring that the discharge assessment is conducted in person by a qualified clinician, even in cases of unexpected discharge, is essential to maintain the integrity of the OASIS data and support the patient’s transition to community. Agencies must prioritize thorough discharge planning and adhere to best practices to avoid penalties and ensure the highest quality of care for their patients.

Disclaimer: This blog is subject to change pending any guidance from CMS. Revised 04.21.2025 based on OASIS Quarterly Update.