by Marian Essey, RN, BSN, COS-C
With the implementation of OASIS all-payer date collection beginning in 2025, CMS has provided guidance through Q&As on important considerations as agencies implement this change. The CMS Home Health All Payer OASIS Q&As are posted in the Downloads section of the CMS OASIS User Manuals webpage.
As finalized in the calendar year (CY) 2023 Home Health final rule and with further details provided in the CY 2025 final rule, OASIS all-payer data collection and submission will be implemented per the following schedule.
- Prior to Jan. 1, 2025 – Medicare and Medicaid Only OASIS Data Collection and Submission
Per the Home Health Conditions of Participation (CoPs) and OASIS guidance, agencies have been required to collect and submit OASIS assessments for all skilled Medicare and/or Medicaid patients, with some exemptions. - Jan. 1-June 30, 2025 – Voluntary Phase-In Period for OASIS All-Payer Data Collection and Submission
For non-Medicare/non-Medicaid patients who are not exempt from OASIS data collection, and who begin receiving home health care services with an OASIS start of care (SOC) M0090 date from January 1, 2025, through June 30, 2025, OASIS data collection and submission are voluntary.When OASIS data collection and submission are started for a non-Medicare/non-Medicaid patient with the SOC OASIS assessment, HHAs may but are not required to complete all subsequent OASIS time point assessments related to the patient’s home health stay (that is, resumption of care, recertification, other follow up, transfer, discharge, and death at home) including assessments completed on or after July 1, 2025.
- Beginning July 1, 2025 – Mandatory OASIS All-Payer Data Collection and Submission
For patients with any pay source who are not exempt from OASIS data collection, and who begin receiving home health care services with an OASIS SOC M0090 date on or after July 1, 2025, OASIS data collection and submission to the Internet Quality Improvement Evaluation System (iQIES) are required. This includes the SOC OASIS as well as any subsequent OASIS time point assessments relevant to the patient’s home health stay (that is, resumption of care, recertification, other follow up, transfer, discharge, and death at home).The criteria for patients exempt from OASIS data collection are not changing and will continue to include patients under 18, patients receiving maternity services, and patients receiving only personal care, housekeeping or chore services.
Learn more on this topic and other cutting edge OASIS guidance in the OASIS Answers Quarterly OASIS Update Webinars. The next webinar is Wednesday, January 22, 2025.
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