Preview Anticipated Changes to OASIS for 2025

by Megan Bernier, MSPT RACT-CT COS-C

New changes for OASIS are planned for Jan. 1, 2025, based on the CY 2023 and CY 2024 Home Health Final Rules.

In the two most recent CMS Home Health Final Rules, CMS announced changes to OASIS data collection for 2025, providing the industry with a full year to prepare for these changes.

End of the Suspension of OASIS Data Collection on Non-Medicare/Non-Medicaid Home Health Patients

In the calendar year (CY) 2023 Home Health Final Rule, CMS finalized the proposal to end the temporary suspension of OASIS Data Collection on non-Medicare/non-Medicaid home health patients and require home health agencies (HHAs) to submit all payer OASIS data.

This was part of the continued effort to align the data collection requirements under the Home Health Quality Reporting Program (HH QRP) with the data collection requirements for other post-acute care settings.

The requirement to report OASIS data on all patients will begin with a two-quarter phase in, meaning that for all patients discharged between January 1, 2025, and June 30, 2025, HHAs will have an opportunity to begin submitting OASIS data. HHAs will be required to submit OASIS data on all patients, regardless of payer, for patients discharged July 1, 2025 or later.

Patients under the age of 18, patients receiving maternity services, and patients receiving only personal care, housekeeping, or chore services will continue to be exempt from OASIS data Collection.

OASIS Instrument Changes Expected for January 1, 2025

In the CY 2024 HH final rule, CMS also finalized several proposals that will require changes to the OASIS data set for January 1, 2025. First, CMS has announced that two OASIS Items, M0110, Episode Timing and M2200, Therapy Need will be removed from OASIS-E.

Additionally, due to the retirement of an OASIS-based quality measure, CMS will removed the GG0130, Self-Care and GG0170, Mobility Discharge Goals from the Start of Care and Resumption of Care OASIS time points.

The final change to OASIS will be the addition of a COVID-19 item to the transfer, death at home, and discharge OASIS time points. This new item will allow for the collection of the OASIS based Patient/Resident COVID-19 Vaccine quality measure.


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