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What is ‘All-Payer OASIS Data Collection and Submission’?

CMS has lifted the long-standing suspension of OASIS requirements for collection of data on non-Medicare/non-Medicaid patients. This means that Medicare-certified home health agencies will be required to collect and submit OASIS data on all patients, regardless of payer. The new guidance is included  in the OASIS-E1 guidance manual and CMS has also released a Q&A…

CMS has lifted the long-standing suspension of OASIS requirements for collection of data on non-Medicare/non-Medicaid patients. This means that Medicare-certified home health agencies will be required to collect and submit OASIS data on all patients, regardless of payer. The new guidance is included  in the OASIS-E1 guidance manual and CMS has also released a Q&A document to address some of the common questions. Below are some of the key points:

  • OASIS data collection on non-Medicare and non-Medicaid patients is based on the Start of Care (SOC) M0090 date.
  • There is a phase-in period from January 1, 2025 – June 30, 2025, where the agency can choose if they want to collect and submit OASIS data on non-Medicare/non-Medicaid patients.
  • OASIS data collection on non-Medicare/non-Medicaid patients will be mandatory beginning July 1, 2025. This is based on the SOC M0090 date.
  • Non-Medicare/non-Medicaid patients with a SOC M0090 date prior to January 1, 2025, do not require collection of OASIS data and will be rejected if submission is attempted to iQIES. While the agency may decide to complete OASIS assessments on a non-Medicare/non-Medicaid patient, no OASIS SOC or subsequent OASIS should be submitted to iQIES for a patient with an OASIS Start of Care (SOC) M0090 prior to January 1, 2025, including any OASIS assessments completed in 2025.
  • Charity, self-pay, no payer are all included as non-Medicare/non/Medicaid for OASIS data collection. If the agency is providing home care services for more than one visit in a quality episode and the patient does not meet one of the exemptions below, OASIS is required regardless of who, if anyone, pays for the care.
  • OASIS exemption criteria have not changed. Patients that are exempt from OASIS data collection include:
    • patients under the age of 18
    • patients receiving only maternity services
    • and patients receiving only personal care, housekeeping, or chore services
  • The OASIS privacy notice must be provided to any patient that OASIS data is collected, including non-Medicare/non-Medicaid patients.
  • Medicaid home health agencies providing care in a state that requires the agency to meet the Medicare Conditions of Participation must collect and submit OASIS data on any patient that does not meet one of the exceptions: under the age of 18, receiving only maternity services, receiving only personal care, housekeeping, or chore services.
  • The guidance for a single visit quality episode has not changed. If OASIS data is collected for a single visit quality episode to meet the requirement of a payer, submission of the OASIS is not expected and a discharge OASIS should not be completed.

Get more information here:

OASIS-E1 Guidance Manual – Chapter 1: OASIS-E1 Manual

CMS Home Health OASIS All Payer Q&As: CMS Home Health OASIS All Payer Q&As