What to Know Before the July 1, 2025 All-Payer OASIS Rollout

by Megan Bernier, MSPT RAC-CT COS-C

July 1st is quickly approaching. Home health agencies will be required to collect and submit OASIS on all patients with few exceptions in the second half of the year. To prepare for a smooth transition, here are some things agencies may want to consider prior to the beginning of the mandatory phase.

As CMS has indicated through rule making and more recently through the CMS Quarterly OASIS Q&As, even after July 1, 2025 there are going to be three types of patients being seen by home health agencies (HHAs).

1. Non-Medicare/non-Medicaid patients who began care prior to January 1, 2025
2. Voluntary patients
3. Mandatory patients

For non-Medicare/non-Medicaid patients who began care prior to January 1, 2025, no OASIS assessments should be submitted at any time during their home health stay. Voluntary patients can be identified as any patient with a non-Medicare/non-Medicaid payer who has January 1, 2025 through June 30, 2025 Start of Care (SOC) M0090 – Date Assessment completed date. For these voluntary patients, all OASIS assessments, even those occurring on or after July 1, 2025 are not required.

Prior to July 1st agencies may want to consider taking the following steps to ensure a smooth transition:

Identify all non-Medicare/non-Medicaid patients who began care before January 1, 2025 and be sure to exclude them from OASIS data submission for the remainder of their home health stay.
Identify all voluntary patients that will still be on service as of July 1, 2025 and determine how your agency plans to address any subsequent assessments for these voluntary patients
Agencies may continue to collect and submit voluntary assessments after July 1st or may choose not to. Ensure clinicians understand your agency’s expectations and policies regarding collecting and submitting OASIS for voluntary patients on/after July 1, 2025.

For all patients with a SOC M0090 date of July 1, 2025, or after, ensure that staff are aware of the guidance related to who requires and who does not require OASIS data collection. The key points here should include:

Understanding the long-standing OASIS exceptions:
- Patients under the age of 18
- Patients receiving maternity services, and
- Patients receiving only personal care, housekeeping services, or chore services
Understanding additional exceptions to OASIS data collection:
- Single visit quality episode guidance applies to all patients
- Loaned employee agreements
Understanding of OASIS requirements:
- OASIS data collection and submission applies to all Medicare-certified Home health agencies (HHAs) that must meet the Medicare home health (HH) Conditions of Participation (CoPs), and Medicaid home health providers in states where that state’s laws require those agencies to meet the Medicare HH CoPs.
- If a patient is requiring “skilled” services, as defined by the Medicare home health benefit then assuming no other exceptions exist, OASIS data collection and submission is required, regardless of the patient payer

If your agency Still have questions about all-payer OASIS requirements or implications? OASIS Answers is here to help! Education related to the transition to all-payer OASIS data collection and submission is covered as part of our 2-day Blueprint for OASIS Accuracy workshop.

We also have provided all-payer updates during our Quarterly OASIS Updates in January and April and will provide additional updates during the July Quarterly OASIS Update.