Home Health Update! All Payor OASIS Completion and Submission

The Essentials:

OASIS submission for all payers begins July 1st, 2025! The “practice time” for OASIS submission for all payors, is nearing halfway point! In the past, only the OASIS submissions for Medicare, Medicaid, and their managed plans were required. 

January 1st, 2025 through June 30th, 2025, is the first time that “another” payor OASIS are allowed to be submitted. During this time, the submission of these OASIS is optional, or in a “practice” timeframe. Beginning July 1st, 2025, Home Health agencies are expected to complete and submit OASIS for all non-exempt patients, no matter who the payor is. 


What Happens Next?

Centers for Medicare & Medicaid Services (CMS) has finalized the end of the temporary suspension of Outcome and Assessment Information Set (OASIS) data collection on non-Medicare/non-Medicaid Home Health Agency (HHA) patients. 


CMS expects to use this all-payor data to gain a better understanding of the overall quality of care, regardless of payer source. At this time, CMS states they will monitor the all-payer OASIS data and will notify providers when a decision is made for future uses of this data for quality or payment purposes. As of the time of this notice, no decisions have been made.


What Does the Timeline Look Like?

NOW through June 30th, 2025:
Agencies are encouraged to start testing their software and systems by submitting other payor OASIS for any SOC (with M0090 on or after 1/1/25). Submission of OASIS for these patients is still optional during this time period.

HHAs need to decide whether to complete any or all non-Medicare/non-Medicaid patients’ subsequent OASIS time point assessments for whose start OASIS were collected during this period. Including those subsequent assessments for prior submissions occurring on or after July 1, 2025.

JULY 1st:
Collect and submit OASIS data for all patients with any pay source, who begin receiving home health care services with an OASIS SOC M0090 date on or after July 1, 2025. Include all subsequent OASIS time point assessments (resumption of care, recertification, other follow-up, transfer, discharge, and death at home).


Next Steps

ONE: Home health agencies should consider gathering OASIS data on all patients, except for the following exclusions:

  • Patients under the age of 18

  • Patients receiving maternity services

  • Patients receiving only personal care, housekeeping, or chore services.

TWO: Voluntarily submit some sample OASIS during the optional timeframe, by choosing any patient with an OASIS SOC M0090 date from January 1-June 30, 2025.

THREE: Ensure your software and processes are ready for the mandatory submission deadline of July 1, 2025. 

Read more here:

Annette Lee

Founder Annette Lee built Provider Insights to give home health and hospice providers peace of mind. She’s had decades of experience at CMS and provided many years of consultancy services—including contracting as a Medicare Administrator with MAC.

She speaks Medicare-ese fluently and knows how to make the most complicated rules make sense for patient-centered providers who don’t have the time to dissect every rule. Agencies that work with Provider Insights can rest assured they’re fully compliant with the regulations that are in place today. And they’ll stay compliant when those regulations change tomorrow.

https://www.providerinsights.com/
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