You might think something as simple as reporting the Start of Care date on the Outcome and Information Assessment Set (OASIS) would be a no-brainer, but it’s one area in which clinicians often seem to stumble.
Clinicians believe they’re simply filling in dates, but in not understanding exactly what is being asked for, they items M0102 and M0104 wrong — particularly if the OASIS is being completed on paper rather than electronically.
The results can create major confusion. It can look as if the agency failed to begin care on the date specified by the physician. It can look like the agency did not begin care within the 48-hour window mandated under the Conditions of Participation set by the Centers for Medicare and Medicaid Services (CMS).
And, once public reporting of measures such as timely initiation of care begins, it may give agencies a huge black eye, burdening them with the reputation of being slow to provide care.
With so much at stake, how is it possible for clinicians to drop the ball on simply recording dates?
“Clinicians don’t seem to know the difference and just put the dates most visible,” explains Kimberly Searcy Gunter, Director of Global Education for Home Health Solutions. “They don’t look back at the referral for confirmation.”
Kimberly and Marti Holthus, a quality mentor at HHS, have put together the following guide to walk clinicians through the process of correctly answering M0102 and M0104, identifying some of the most commonly made errors.
It’s either-or, not both
Correctly answering M0102 and M0104 begins with understanding that these two items constitute an either-or question. A date will be entered into either M0102 or M0104 but never into both.
To determine whether a date will be entered into M0102 or M0104, use these two questions.
1. Did the physician specify the SOC date?
Then complete M0102 and skip M0104.
2. Did the physician NOT specify the SOC date?
Then only the referral date needs to be recorded. The clinician should mark M0102 N/A and complete M0104 instead.
Accuracy in answering these items requires actually looking at the physician referral to determine whether a specific date has been ordered for home health services to begin, according to Kimberly.
Clinicians sometimes incorrectly believe M0102 is simply asking for the date the agency began delivery of services to the patient – but it actually seeks to determine something else. The real question is whether the physician told the agency to begin services at a specific time, rather than leaving the SOC to the discretion of the agency within its 48- hour mandate. This is an important distinction.
In most cases, clinicians will need to skip M0102 and move on to M0104.
“Many physicians don’t actually order a specific date, so M0102 would be left blank,” Kimberly says. “M0104 would be filled out instead with the referral date.”
Physicians usually do not see the need to specify a SOC date because agencies are mandated by the Conditions of Participation set by CMS to begin care within 48 hours of the date the patient is referred to home health care, or within 48 hours of the patient’s return home after a stay in an in-patient facility. They physician knows that the patient will be seen within the mandated time frame.
However, under certain circumstances, it may be more important for home health to visit the patient quickly. In that case, the physician will direct an agency to begin care on a specific date. This constitutes a physician-ordered SOC and means M0102 will need to be filled out.
Note that under this situation, when M0102 has been filled out, it is no longer necessary to fill out M0104.
Here is a specific breakdown of the differences between M0102 and M0104 and some of the common problems associated with each.
M0102 is intended to record the date of physician-ordered SOC or ROC (Resumption of Care). It refers to the specific date the
physician has instructed the agency to provide the first covered service, regardless of the type of services ordered. It can apply, for example, to therapy only.
This item is to be completed ONLY if the physician has indicated a specific date for care to begin. In order to be considered a physician-ordered SOC date, the physician must give the agency one specific date to initiate care, not a range of dates.
Otherwise, if the physician does not specify a specific date to initiate home services, M0102 will be marked N/A, and the agency will proceed with its mandate to provide the initial assessment within 48 hours of the referral or within 48 hours of the patient’s return home from the inpatient facility.
An example of the need for an agency to complete M0102 would be a case in which the patient is to receive IV antibiotics at home, and the physician wants care to begin on a specific date. The start date the agency is to begin administering IV antibiotics must be documented in the physician’s orders in order for M0102 to be filled out.
If the physician’s orders do not provide the specific date for IV antibiotics to begin, M0102 should be marked N.A.
Common M0102 Mistakes:
1. Putting the SOC date here. M0102 does not want to know when your agency began delivering care to the patient. It only wants to know whether the physician told your agency to begin delivering care on a specific day.
2. Putting the Referral Date here. M0102 does not want to know when the patient was referred to your agency. If you enter the referral date here, you are erroneously saying that the physician told you to begin care on that date and you did not comply with the order.
This item will only be completed when M0102 has been marked N/A.
If a single date to initiate services has NOT been provided by the physician, the agency is mandated to provide services within 48 hours of the date the patient was referred to home health or returned home after a stay at an in-patient facility.
M0104 is intended to record that Date of Referral.
The Date of Referral is when the agency receives the order from the physician for home health services. Receiving the order from the physician starts the 48-hour clock ticking for the agency.
It’s important to note that the Date of Referral will be the most recent date that verbal, written, or electronic authorization to begin home care was received by the home health agency.
Also note that only the physician’s authorization may be used as the Date of Referral. The OASIS manual specifically says that authorization “does not refer to calls or documentation from others such as assisted living facility staff or family who contact the agency to prepare the agency for possible admission.”
Common M1040 Mistakes:
1. Double dates. Don’t enter a date here when you have also entered a date under M0102. Only one of these items should be filled out. Remember, M0102 must be marked N/A. if you are entering a date into M0104.
2. Using the patient’s payer authorization date. The date authorization was received from the patient’s payer is NOT the date of the referral. The date the Medicare Advantage case manager authorizes service, for example, is not considered a referral date.
3. Entering an out-of-compliance date. Agencies need to keep in mind that the date in M0104 should always be the date the agency received the most updated/revised information from the referral source. Otherwise, your agency may be out of compliance with the 48-hour mandate.
Marti Holthus offers these two examples of how the date entered into M0104 might be out of compliance:
“Let’s say an agency receives a fax from the hospital on 7/14 with a referral for home health. The anticipated discharge date is 7/16. Then the agency receives another fax from the hospital on 7/16 saying the patient will be discharged on 7/17. The agency does the SOC on 7/18. Even though the agency initially received the order on 7/14, the correct date for M0104 will be 7/16 because that is when the revised info was received from the hospital.”
Using the original date would place the agency’s SOC date out of compliance in this example.
Sometimes, it isn’t a revised discharge date that delays an agency’s SOC, but a request from a patient to wait to be seen.
“Let’s say you received a referral on 7/14, but the patient did not want to been seen until 7/17. Many agencies will put 7/17 in M0102; however, this is not appropriate. They need to obtain approval of the SOC delay from the physician, and then 7/17 could be used in M0102,” Marti explains. “Since the agency is out of compliance with the 48-hour mandate, they would need to document why.”