OASIS and Collaboration…Must We Collaborate?

by Megan Bernier MSPT, RAC-CT, COS-C

Can your agency require clinicians to complete OASIS using only their own assessment findings, even though CMS allows collaboration?

If you’ve been working in home health for some time you may remember that there was a time when completing the comprehensive assessment including OASIS was the responsibility of the assessing clinician only (a.k.a. the one clinician convention). Assessing clinicians could only code OASIS based on their direct observation and were not allowed to use information from other clinicians that had gathered information within an assessment timeframe.

Since January 1, 2018, while the comprehensive assessment continues to be the responsibility of one clinician, CMS has allowed assessing clinicians to elicit feedback from other agency staff in order to complete any or all OASIS items. But does that mean we HAVE to use collaboration?

In the April 2026 CMS OASIS Quarterly Q&As, CMS clarified that while the assessing clinician may collaborate to collect data for any and all OASIS items, if agency policy allows. If desired, agencies may continue to limit the OASIS to only that data directly assessed and collected by the assessing clinician.

Interested in learning about the most recent OASIS-E2 guidance? Consider joining OASIS Answers at an upcoming Blueprint for OASIS Accuracy workshop.

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