Medication Management & OASIS

The Quarterly OASIS Q&As were released in January.  Interestingly, there were a number of questions regarding medication management, specifically OASIS items M2020 and M2030.  Determination of the patient’s ability to manage oral and/or injectable medications can be tricky for the assessing clinician. Direct observation is the preferred assessment method.  Clinicians need to observe the patient’s ability to navigate his/her way to their meds which may be in a variety of places.  Assessment includes how the patient negotiates obstacles in the home.  Other factors such as cognitive ability, vision, manual dexterity, and presence of the medication in the home must be taken into account.  Several Q&As involved various situations such as a medication being locked up, not picked up from the pharmacy, or patient inability to afford the prescribed drug.  The suggested strategies focused solely on the patient’s ability.  In these cases, the guidance allows non-observation assessment techniques such as reports from the patient or others. Some additional thoughts not included in the Q&As are these: document the assessment technique used, explain reasons for patient limitations, and notify the ordering physician/allowed practitioner of any medication non-compliance regardless of reason.  These notations within the patient’s clinical record will serve to strengthen medical necessity.