by Megan Bernier, MSPT RAC-CT COS-C
With July 1, 2025, and the implementation of mandatory OASIS data collection for all payers swiftly approaching, home health agencies (HHAs) may find themselves questioning how to identify if a patient requires OASIS data collection and submission.
As finalized in the Home Health CY 2023 Final Rule, CMS ended the temporary suspension of OASIS data collection for non-Medicare/non-Medicaid patients as of July 1, 2025. With the end of this suspension, OASIS data collection will now be required for all patients regardless of payer.
But what does “regardless of payer” really mean? HHAs see a wide range of patients with varying payers and sometimes no payers. Is there a way to easily identify which of these patients required OASIS?
In the recent CMS OASIS Quarterly Q&As, as well as to the All-payer Q&A document that CMS released in November 2024, there have been several clarifications issued to help agencies determine which patients require OASIS.
First, if home care services are being provided by a Medicare-certified home health agency or a Medicaid home health provider in states where those agencies are required to meet the Medicare home health Conditions of Participation, for more than on visit in the quality episode, then OASIS data collection and submission is required regardless of who, if anyone, pays the agency for the care.
This means that if the services are being paid by an insurance company, or through a charity or community waiver program, or if the patient has no payer or is self-paying, OASIS data collection and submission is required.
Most recently, as identified in the April 2025 CMS OASIS Quarterly Q&As, all patients who meet the definition of receiving “skilled services” as defined by Chapter 7 of the Medicare Benefit policy require OASIS data collection and submission. This publication can be found at on the CMS website.
However, OASIS is not required if the patient is:
Additionally, as we learned in the April 2025 CMS OASIS Quarterly Q&As if HHA staff are contracted with another company, for example a pharmacy company, to provide services under a loaned employee agreement then OASIS is not required.
As we approach the beginning of mandatory data collection it will be important for HHAs and clinicians to understand the rules and regulations related to OASIS data collection.
The information in this blog is tiny an example of the enormous amount of information recently shared with the home health industry on the recent OASIS Answers Quarterly OASIS Update webinar. The April 16th, 2025 webinar included information on:
If you’re kicking yourself that you missed this webinar, you’re not too late! You can watch the recording or consider purchasing the 2025 bundle (at the bottom of the screen) to get the recordings for January and April and the live and recorded sessions for July and October 2025.
Stay up to date on new CMS information related to HHVBP and OASIS accuracy.
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