by Lori Marmon PT, MBA, COS-C
The home health industry is approaching the era of OASIS data collection and submission for all. HHAs are days away from the start of the voluntary phase-in for “all-payer” OASIS data collection and submission.
As identified in the Home Health Final Rule for CY2025, the voluntary phase-in begins January 1, 2025. With the voluntary phase-in, agencies have the opportunity to elect to collect and submit any and all OASIS data for payers other than Medicare and Medicaid, but it is not yet REQUIRED.
With the voluntary phase-in, home health agencies (HHAs) may complete and submit OASIS at any time point for any patient with a start of care (SOC) M0090 – Date Assessment Completed of January 1, 2025 or later. However, since OASIS collection and submission for non-Medicare/non-Medicaid patients is not mandatory until July 1, 2025, agencies can continue to only collect and submit OASIS for those patients that require OASIS data collection (i.e., Skilled Medicare and Medicaid patients that do no meet the OASIS exemptions).
Agencies who do elect to begin collecting and submitting OASIS on their non-Medicare/non-Medicaid patients should also keep in mind that even if they complete a SOC OASIS for these patients they are not obligated to complete subsequent assessments, including assessments that would fall on or after OASIS data collection becomes mandatory.
Beginning July 1, 2025, HHAs will be required to collect and submit OASIS data for all patients regardless of payer, who have an OASIS SOC M0090 date of July 1, 2025 or later.
For all patients with a SOC of July 1, 2025 or later, OASIS data collection and submission is mandated to include ALL subsequent OASIS time points as well (resumption of care (ROC), recertification, other follow-up, transfer, discharge and death at home).
With this transition to OASIS data collection and submission for all patients, a few things remain constant regardless of the date:
- HHAs will continue to collect and submit OASIS for all skilled Medicare and/or Medicaid patients
- The patients EXCLUDED from OASIS data collection and submission also remain the same regardless of the timing. OASIS data collection and submission is not required for
- Patients under the age of 18
- Patients receiving maternity services
- Patients receiving only personal care, housekeeping or chore services
With this information HHAs can prepare for any staff education or process updates for the additional collection and submission requirements.
The time is fast approaching for this transition. Is your agency ready? Does your staff know what to expect and when? Planning and preparation may help make this transition a little smoother, but questions can still arise during the implementation of new processes. There are resources available to HHAs working through this implementation. The CMS Home Health All Payer OASIS Q&As are posted in the Downloads section of the CMS OASIS User Manuals webpage.
Send questions to the Home Health Quality Help Desk at homehealthqualityquestions@cms.hhs.gov
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