Medication Reconciliation in Home Health and OASIS E-1 Assessment Applicability

Medication safety is one of the most pressing challenges in home health care. Patients often transition from hospitals, skilled nursing facilities, or physician offices to the home environment with complex medication regimens. Without careful oversight, errors such as duplications, omissions, or incorrect dosing can easily occur—placing patients at risk of adverse events, hospital readmissions, or even mortality.

To address these risks, medication reconciliation has become a central requirement in home health practice, directly tied to compliance, quality, and patient safety. In parallel, the OASIS E-1 assessment plays a critical role in how agencies document medication management and demonstrate compliance with Medicare’s Conditions of Participation (CoPs).

This article examines the importance of medication reconciliation in home health, the regulatory and compliance framework, and how the OASIS E-1 assessment applies to medication documentation and quality reporting.

What Is Medication Reconciliation?

Medication reconciliation is the process of comparing a patient’s current medication orders with all medications the patient has been taking. This includes:

• Prescription drugs

• Over-the-counter (OTC) medications

• Herbal supplements and vitamins

• PRN (as-needed) medications

The goal is to identify and resolve discrepancies, ensuring patients are on the right medication, in the right dose, at the right time, for the right indication.

Why Medication Reconciliation Matters in Home Health

Medication reconciliation has a direct impact on patient outcomes, compliance, and financial performance.

• Reduces Adverse Drug Events (ADEs): ADEs are a leading cause of hospital readmissions. Home health agencies play a key role in catching errors early.

• Supports Value-Based Care: Under CMS’s Home Health Value-Based Purchasing (HHVBP) model, reducing avoidable hospitalizations directly affects reimbursement.

• Meets CoPs Requirements: CMS requires agencies to conduct medication reconciliation during Start of Care (SOC) and throughout the episode of care.

• Improves Patient Education: Medication reconciliation provides an opportunity for clinicians to educate patients and caregivers about safe medication practices.

Regulatory Compliance and Medication Reconciliation

The Medicare CoPs (§484.55 Comprehensive Assessment) mandate that home health agencies perform a comprehensive medication review as part of the OASIS assessment. This requirement includes:

• Reviewing all current medications

• Reconciling with physician orders

• Identifying potential drug interactions or duplications

• Documenting findings in the patient record

• Communicating concerns with the physician and interdisciplinary team

Failure to reconcile medications appropriately is one of the top survey deficiencies for home health agencies.

The Role of the OASIS E-1 Assessment

The OASIS (Outcome and Assessment Information Set) E-1 is CMS’s standardized tool for collecting patient data. Effective January 2025, OASIS E-1 emphasizes functional, clinical, and social determinants of health while maintaining critical items related to medication management.

Key OASIS E-1 Items Related to Medication Reconciliation

• M2001: Drug Regimen Review – Assesses whether a medication review was completed at SOC or resumption of care.

• M2003: Medication Follow-Up – Identifies if the agency contacted a physician for medication issues identified.

• M2005: Medication Intervention – Evaluates if timely follow-up interventions were implemented when discrepancies were found.

These measures are directly tied to Home Health Quality Reporting Program (HHQRP) outcomes, meaning incomplete or inaccurate documentation can impact agency star ratings and reimbursement.

Common Medication Reconciliation Errors in Home Health

Agencies frequently encounter the following challenges during reconciliation:

1. Incomplete Medication Lists – Patients or caregivers may not disclose OTC drugs or supplements.

2. Transition of Care Gaps – Hospitals discharge patients with medication changes that never reach the home health team.

3. Unclear Physician Orders – Verbal orders may be poorly documented or delayed in transcription.

4. Polypharmacy Risks – Older adults often take 10+ medications, increasing the risk of interactions.

5. Patient Non-Adherence – Even with accurate orders, patients may not take medications correctly.

Documentation audits often reveal that these issues are either not properly identified or not communicated to the physician, leading to compliance deficiencies.

Best Practices for Medication Reconciliation in Home Health

To strengthen medication reconciliation and align with OASIS E-1, agencies should adopt the following strategies:

1. Standardize the Process

• Use checklists or EHR-integrated forms to ensure every step of the reconciliation process is completed.

• Train staff to collect medication information consistently.

2. Engage Patients and Caregivers

• Ask patients to bring all medications (including supplements) to the SOC visit.

• Use “teach-back” methods to confirm patient understanding of medication instructions.

3. Collaborate with Physicians and Pharmacies

• Establish communication protocols for rapid clarification of discrepancies.

• Partner with local pharmacies to share updated medication lists.

4. Leverage Technology

• Use EHR alerts to flag missing or conflicting medications.

• Consider telehealth check-ins for medication adherence monitoring.

5. Document Thoroughly

• Document discrepancies, communication with physicians, and interventions in real time.

• Ensure OASIS items (M2001, M2003, M2005) are completed accurately and timely.

Medication Reconciliation and Billing Accuracy

Accurate medication documentation also supports billing accuracy:

• Supports Skilled Services: Demonstrates medical necessity for nursing visits, such as teaching and monitoring medication regimens.

• Reduces Denials: Complete OASIS documentation supports claim submission under PDGM (Patient-Driven Groupings Model).

• Protects Against Audits: Thorough reconciliation documentation helps agencies defend against ADRs (Additional Documentation Requests) and UPIC audits.

Integrating Medication Reconciliation into QAPI

Medication reconciliation should be part of every agency’s Quality Assessment and Performance Improvement (QAPI) program:

• Track rates of adverse drug events (ADEs) and hospital readmissions linked to medication errors.

• Audit OASIS documentation for M2001, M2003, and M2005 accuracy.

• Implement performance improvement projects (PIPs) targeting medication safety.

Agencies that embed reconciliation into QAPI not only stay compliant but also improve patient outcomes and financial performance.

Innovative Approaches to Medication Reconciliation

Forward-thinking agencies are going beyond the basics with creative strategies:

• Medication Therapy Management (MTM): Partnering with pharmacists to conduct in-depth reviews.

• Digital Medication Apps: Providing patients with reminders and dosage trackers.

• Home Delivery Programs: Coordinating directly with pharmacies to simplify patient access.

• Interdisciplinary Collaboration: Engaging nurses, therapists, and aides to reinforce medication safety across all visits.

Conclusion

Medication reconciliation is more than a compliance requirement—it is a critical patient safety initiative that reduces errors, prevents hospitalizations, and ensures accurate billing. With the rollout of OASIS E-1, agencies must pay close attention to how medication documentation supports both quality outcomes and regulatory compliance.

By standardizing processes, leveraging technology, engaging patients, and integrating reconciliation into QAPI, home health agencies can master this essential function. Done well, medication reconciliation not only protects patients but also strengthens the agency’s compliance posture, survey readiness, and financial performance.