by Megan Bernier, MSPT, RAC-CT, CHS-C, COS-C
On July 2nd, 2026, CMS issued the Expanded HHVBP Model June 2026 Newsletter. This newsletter contains an HHQRP Spotlight section that announcing all-payer changes related to the HH QRP APU.
Home health agencies (HHAs) have been collecting and submitting OASIS data on all patients, regardless of payer, who are not exempt from OASIS data collection since July 1, 2025, however up until now CMS has not announced any intended use for the non-Medicare/non-Medicaid OASIS data.
In the June 2026 Expanded HHVBP Model Newsletter, CMS has announced that to calculate APU, they intend to include patient data from all non-Medicare/non-Medicaid patients who begin receiving skilled home health care services with an OASIS SOC M0090 date on or after January 1, 2027.
Further clarification is provided that if the M0090 date for the SOC is before January 1, 2027 for a non-Medicare/non-Medicaid patient, no OASIS data from any of their time points throughout their entire home health admission will be used for APU purposes, including any assessments that may be completed on or after January 1, 2027.
The transition to using all-payer OASIS data for APU calculation does not impact how assessment data of skilled Medicare/Medicaid patients is utilized.
HHAs will still be required to achieve a quality reporting compliance rate of 90 percent (90%) or more for all submitted OASIS data, regardless of payer, as calculated using the QAO metric:

For more information on the HH QRP quality reporting requirements, please see the HH QRP Quality Reporting Requirements webpage.
To learn more about this late breaking announcement as well as other developing home health industry news, consider joining OASIS Answers on the upcoming July 2026 Quarterly OASIS Update on July 22nd, 2026.
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