August 18 2025
OASIS Answers
Categories: OASIS

The Most Misinterpreted OASIS Guidance (and What It Really Means)

by Megan Bernier, MSPT RAC-CT COS-C

OASIS guidance is often confusing and can be easy to misinterpret. Without a strong foundational knowledge of OASIS, clinicians can easily find OASIS data collection overwhelming and frustrating. One question that gets asked frequently at our Blueprint for OASIS Accuracy Programs is what disciplines can complete subsequent OASIS assessments.

OASIS guidance is very specific on who can complete a Start of Care (SOC) OASIS. For SOC, it all depends on the disciplines that are included on the referral. In fact, there is a whole section in the Chapter 1 of the OASIS Guidance Manual devoted to who can complete OASIS.

What is not as prevalent in the guidance manual is who can complete subsequent assessments, those that occur after the SOC. Based on questions OASIS Answers has received, there are often misconception among home health providers that if nursing is involved at the time of a subsequent OASIS time point, resumption of care (ROC), recertification etc., then the nurse must complete the OASIS. Not true!

It is unclear where this misconception originated, as longstanding guidance in the OASIS Guidance manual and the CMS OASIS Q&As refutes it.

In OASIS Guidance Manual, Chapter 3, Coding Tips for item M0080 – Discipline of Person Completing Assessment, there is tip that states “According to the comprehensive assessment regulation, when both the RN and PT/SLP/OT are ordered on the initial referral, the RN must perform the SOC comprehensive assessment including OASIS. An RN, PT, SLP, or OT may perform subsequent assessments.”

We can also find this guidance in multiple locations throughout the CMS OASIS Q&As. Category 2-– Comprehensive Assessment, Q10 also indicates that when both nursing and PT are involved in the patient’s stay, while the nurse would be responsible for the SOC comprehensive assessment including OASIS, if nursing was on the initial referral, either discipline may perform subsequent assessments.

Q23.9 in Category 4b – OASIS Data Items provides the same guidance related to a Resumption of Care (ROC) scenario when both an RN and PT are involved at the time of the ROC.

In short, while guidance is quite specific on the disciplines who must complete the SOC OASIS, after the SOC time point, it is left to the discrepancy of the agency on who completes the subsequent assessments since there is no mandate for this.

For more answers to your OASIS questions and to find out what guidance you might be “misinterpreting” consider joining us at an upcoming Blueprint for OASIS Accuracy Program where OASIS Answers will make learning OASIS-E1 as easy as possible and answer your questions based on the most recent CMS guidelines.