by Megan Bernier, MSPT, RAC-CT, COS-C
When is OASIS data collected as part of the comprehensive assessment?
As stated in the Medicare Home Health Conditions of Participation (CoP) 484.55, each patient must receive, and the agency must provide, a patient-specific, comprehensive assessment. The CoPs also state that the comprehensive assessment must include the current version of the OASIS items, using the language and groupings of the OASIS items.
The comprehensive assessment including OASIS data collection requirements, apply to Medicare certified home health agencies (HHAs) and to Medicaid home health providers in States where those agencies are required to meet the Medicare Conditions of Participation.
The comprehensive assessment, including OASIS, is required to be collected for all skilled Medicare, Medicaid, and Medicare or Medicaid managed care patients unless there is an applicable exclusion. Skilled Medicare and/or Medicaid patients who are excluded from OASIS requirements include:
- Patients under the age of 18
- Patients receiving pre- & post-partum maternity services
- Patients receiving personal care, housekeeping services, or chore services
OASIS Time Points and the Comprehensive Assessment
OASIS data are collected for skilled Medicare and Medicaid patients at eight specific time points:
- Start of Care
- Resumption of Care
- Recertification (follow-up) Reassessment
- Other Follow-up
- Transferred to an Inpatient Facility – Patient not Discharged from Agency
- Transferred to an Inpatient Facility – Patient Discharged from Agency
- Death at Home
- Discharge from agency
All OASIS assessments, except Transfer to Inpatient Facility and Death at Home, require the qualified clinician to have an in-person encounter with the patient during an in-home visit. The Transfer to an Inpatient Facility and Death at Home time points require collection of limited OASIS data (most of which may be obtained through a telephone call).
Only time points that require an in-person encounter with the patient require the completion of the comprehensive assessment, including OASIS. The time points are:
- Start of Care
- Resumption of Care
- Recertification (follow-up) Reassessment
- Other Follow-up
- Discharge from agency
For the above listed time points that require the OASIS to be part of the comprehensive assessment it is important to note that OASIS is not intended to represent the comprehensive assessment in and of itself, and collection of data other than OASIS is required to comply with the CoPs.
The following table depicts the requirements for OASIS data collection, by time point, and as required for the completion of the comprehensive assessment:
| Data Collection Time Point | Completion of the Comprehensive Assessment, including OASIS, Required | Completion of OASIS (NOT part of the comprehensive assessment), Required |
| Start of Care | X | |
| Resumption of Care | X | |
| Recertification (follow-up) Reassessment | X | |
| Other Follow-up | X | |
| Transferred to an Inpatient Facility – Patient not Discharged from Agency | X | |
| Transferred to an Inpatient Facility – Patient Discharged from Agency | X | |
| Death at Home | X | |
| Discharge from Agency | X |
More information on the different OASIS time points can be found in the OASIS-E Guidance Manual found here: OASIS User Manuals | CMS and the CMS OASIS Q&As found here: home-health-agency-hha-providers Reference & Manuals | QIES Technical Support Office (cms.gov)
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