June 29 2026
OASIS Answers
Categories: OASIS

M1840 Toilet Transferring: Three Coding Concepts Every Clinician Should Know

by Lori A Marmon, MBA, PT, CHS-C, COS-C

When assessing and coding a patient’s ability to complete the toileting transfer on the OASIS, clinicians must consider numerous variables. These may include the patient’s environment, medical restrictions, available equipment, caregiver support, and the patient’s physical and cognitive ability. In addition, clinicians may encounter “scrubber” alerts or quality assurance feedback that may create distractions and complicate the coding process. A strong understanding of CMS guidance is essential to accurately determine the correct OASIS response.

Three Key Points for Accurate M1840 Coding

1. If the patient can safely get to and from the toilet and transfer on and off the toilet, they can use the toilet.

Select Response 0 when the patient completes the task independently, without any human assistance.
Select Response 1 when the patient requires any level of hands-on assistance, standby assistance, verbal cueing, or reminders. Response 1 is used when the patient requires assistance to get to and from the toilet, or assistance to get on and off the toilet, or if they require assistance to get to and from AND on and off the toilet.

(CMS OASIS Q&As, Category 4b, Q148.2)

2. If the patient can safely get to and from the toilet and transfer with assistance, Response 1 should be selected regardless of caregiver availability.

M1840 reflects the patient’s ability, not whether assistance is consistently available in the home.
The code should be based on what the patient is capable of doing with the necessary assistance, not on what they may do out of necessity when assistance is unavailable. For example, this guidance remains true even when the patient, who is able to get to/from and/or on off a toilet with assistance, uses a bedside commode (BSC) or urinal when a caregiver is not present.

(CMS OASIS Q&As, Category 4b, Q146)

3. Patients with a urinary catheter can still be assessed for M1840.

Clinicians should evaluate the patient’s ability to get to and from the toilet and transfer on and off the toilet, regardless of whether the patient uses the toilet for urinary elimination.
The item measures the patient’s toileting transfer ability and can be assessed even when urinary elimination occurs through a catheter.

(CMS OASIS Q&As, Category 4b, Q142)

Maintaining consistency with CMS guidance can be challenging when clinicians are faced with numerous recommendations, edits, and review comments. Achieving accurate OASIS coding requires confidence, critical thinking, and a solid mastery of the guidance.

If you or your staff would like to strengthen your ability to navigate conflicting feedback, minimize distractions, and focus on coding accuracy, join OASIS Answers for a Blueprint for OASIS Accuracy workshop and immerse yourself in engaging, practical OASIS education.