November 3 2025
OASIS Answers
Categories: OASIS

OTs and OASIS Assessments: CMS Expands Role in Start of Care

by Megan Bernier, MSPT RAC-CT COS-C

Overview: OTs and Their Expanding Role in OASIS Assessments

Occupational Therapists (OTs) have historically played a limited role in completing OASIS assessments for home health agencies (HHAs). However, recent updates to the Conditions of Participation (CoPs) and OASIS guidance have expanded when and how OTs may complete Start of Care (SOC) assessments.

These changes strengthen the role of OTs in home health care and offer agencies more flexibility while maintaining compliance with CMS regulations.

Who Can Complete OASIS Assessments and When

CMS rules specify which qualified disciplines may perform OASIS assessments and under what circumstances.

When nursing is ordered at referral, only nursing can complete the initial assessment and comprehensive Start of Care (SOC) assessment, including OASIS.
For therapy-only cases (when nursing is not ordered), physical therapists (PTs) and speech-language pathologists (SLPs) have long been able to perform these assessments.
In the past, OTs could perform subsequent OASIS assessments—such as Resumption of Care, Follow-Up, Transfer, Death at Home, and Discharge—but not SOC assessments.

Under previous regulations, the need for OT services alone did not establish patient eligibility for home health care at SOC. This meant OTs could only complete follow-up or discharge assessments after eligibility had already been established by another qualifying discipline (nursing, PT, or SLP).

Key Regulatory Update: OTs Can Now Complete Start of Care (SOC) Assessments

Effective January 1, 2022, CMS updated the CoPs to expand OT participation in Start of Care. Under the new rule, OTs may complete the initial assessment visit and the comprehensive SOC OASIS, but only under specific conditions.

Conditions for OTs to Complete the SOC OASIS

To comply with CMS regulations, all of the following must be true:

OT is included on the referral
Nursing is not included on the referral
Either PT and/or SLP is also included on the referral

This change recognizes the vital role of OTs in evaluating patient needs at the beginning of home health services and provides agencies greater flexibility when assigning qualified clinicians to perform the SOC.

Clarifications from CMS: OT SOCs and Pay Source Changes

Since this regulatory update, CMS has continued to issue clarifications in its Quarterly OASIS Q&As, addressing how OTs may perform SOC OASIS assessments when payer sources change during an active episode of care.

April 2025 CMS Q&A: OT Completing SOC After Medicare Advantage to FFS Change

In the April 2025 Quarterly OASIS Q&As, CMS clarified that when a patient transitions from Medicare Advantage to Medicare Fee-for-Service (FFS) while already receiving services—and OT is the only active discipline—the OT may complete the SOC OASIS.

Because the original home health eligibility remains uninterrupted, the OT can complete the SOC OASIS and continue providing care as the sole active discipline for the remainder of the episode.

July 2025 CMS Q&A: Guidance for FFS to Medicare Advantage Changes

The July 2025 CMS Quarterly OASIS Q&As expanded on this guidance to include payer changes in the opposite direction—from Medicare FFS to Medicare Advantage.

While a new SOC OASIS is not required for this type of payer change, CMS clarified that if the agency chooses to complete one and OT is the only active discipline, the OT may perform the SOC OASIS and continue providing care as the only active clinician.

Summary: What Home Health Agencies Should Know

These updates reflect CMS’s recognition of the expanding and essential role of OTs in home health.

OTs can now perform SOC OASIS assessments under specific conditions when nursing is not ordered and PT or SLP is included on the referral.
Payer transitions do not interrupt eligibility, allowing OTs to maintain care continuity and compliance.
HHAs should ensure internal policies align with the latest CMS guidance and educate staff on when OTs are qualified to complete OASIS assessments.

By staying up to date with these evolving regulations, agencies can ensure accuracy, compliance, and optimal patient outcomes.

We always encourage home health clinicians to stay up to date on all things OASIS and know that at times it can be a struggle to keep all the moving OASIS pieces straight. OASIS Answers is here to help answer your questions and provide you and your agency with the most up-to-date guidance through our 2-day Blueprint for OASIS Accuracy program.