Robin Dowell, Office of Clinical Standards at CMS, responded to our letter asking for guidance on the fall risk assessment dilemma this morning. I plan to respond to Ms. Dowell (who I mentioned has been a great resource for SHP in the past), but I'd like to get your reactions to the letter first, so I can incorporate your feedback. Here's the response:

CMS Letter Response to SHP Re: Fall Risk Assessment

Dear Ms. Rosenblum,

Thank you for writing to express your concern about appropriate documentation of OASIS-C item M1910 (Falls Risk Assessment) for non-ambulatory patients.

The use of a falls risk assessment that is both standardized and validated was required by the National Quality Forum in their endorsement of the Home Health measure “Falls Risk Conducted for Patients 65 and over” in 2009. Since that time, CMS has been aware of the challenges inherent in conducting a standardized, validated risk assessment for home health patients, particularly those who are non-ambulatory.

CMS has addressed this topic in the OASIS-C Guidance Manual, which states that, “CMS does not mandate that clinicians conduct falls risk screening for all patients, nor is there a mandate for the use of a specific tool.” In addition, guidance for M1910 was revised in January 2011 to include a bullet specifically stating that the clinician should select Response 0 [No]... “if the patient is not able to participate in tasks required to allow the completion and scoring of the standardized assessment(s) that the agency chooses to utilize.” This guidance directly addresses the question of how to respond when the fall risk assessment used by an agency is not appropriate for a specific patient due to the patient's physical or mental impairment.The manual also contains language reminding agencies that OASIS data must be accurate and complete in order to meet the Conditions of Participation.

CMS is engaged in a continuing process of evaluating and revising the OASIS data set and working with the National Quality Forum to maintain and improve OASIS-based home health quality measures. The availability of a fall risk assessment that has been validated in community-dwelling elders, uses a standardized rating scale and is appropriate for non-ambulatory patients continues to be a topic under discussion. Any further guidance or changes to the data set or measures related to this issue will be conveyed to agencies and the public via the channels developed for this purpose, such as the Home Health, Hospice, and DME Open Door Forum and the CMS website at www.cms.gov.

Robin Dowell

QMHAG, OCSQ

Centers for Medicare & Medicaid Services (CMS)