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This Isn’t in My Job Description

Posted on January 25, 2010 in Coding Education 

by Jennifer Warfield, RN, BSN, HCS-D, COS-C

"This isn't in my job description." Whether a co-worker, supervisor or an owner, we have all probably heard this term before. If you're like me, the comment, "this isn't in my job description," probably rubs you the wrong way.

If you have reviewed OASIS-C thoroughly, I have no doubt that you have noted at least a couple of areas which may cause some clinicians to make such a comment -- or at least think it. In fact, CMS reported even before OASIS-C was implemented on January 1, 2010, that it had already received numerous comments and questions about who is qualified to answer certain items on OASIS-C. It's not that the clinician doesn't want to do the screening. Rather, the clinician is questioning whether or not he or she is qualified or not.

For example:
M1730 (Depression Screening) asks clinicians to essentially make a determination on whether a patient meets the criteria for further evaluation of depression symptoms by using a standardized tool. This tool asks only these two questions:

In the past two weeks, how often are you bothered by:
- Little interest or pleasure in doing things?
- Feeling down, depressed or hopeless?

A formal depression screening is not mandated in OASIS-C, and if your agency chooses to do a screening, the PHQ-2 tool is suggested. When using PHQ-2's scale, if a patient scores a 3 or greater, he or she meets the requirement for further evaluation of depression symptoms. The clinician conducting the comprehensive assessment might very well have reason to question if he or she qualifies to make the determination for further evaluation. CMS's rebuttal is that the PHQ-2 tool is standardized and used in many healthcare settings already. Therefore, the response is that any clinician qualified to do a comprehensive assessment, is qualified to ask these two questions.

In the weeks and months to come, I'm sure there will be more of these gray areas to contemplate.

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