Starting July 1, 2025, home health agencies (HHAs) are required to collect and submit OASIS data for all patients regardless of payer, with a few exceptions. Here is a comprehensive guide with key things to remember and next steps to help ensure a smooth transition.
Categorize patients by OASIS requirement
Even after the new rules take effect, there will still be three categories of patients based on payer type and start of care (SOC) date. Make sure all clinicians understand which patients require OASIS collection starting July 1, and which ones are exempt.
2. Excluded Patients
- Who: Non-Medicare/non-Medicaid patients who started care before January 1, 2025
- Requirement: No OASIS submission required at any point during their care.
- Action Step: Identify which non-Medicare/non-Medicaid patients began care before Jan 1, 2025. Flag them to ensure OASIS is not submitted.
2. Patients under voluntary OASIS submission
- Who: Non-Medicare/non-Medicaid patients with SOC (M0090) dates between January 1 and June 30, 2025
- Requirement: OASIS is optional—even after July 1, 2025.
- Action step: Determine which of these patients will still be active after July 1, 2025. Decide whether your agency will continue submitting OASIS for them—and communicate this clearly to your staff.
3. Patients under mandatory OASIS submission
- Who: Any patient with a SOC date of July 1, 2025 or later, unless they qualify for an exception
- Requirement: OASIS must be collected and submitted
- Action step: Make sure all clinicians understand which patients require OASIS collection starting July 1, and which ones are exempt.
With the all-payer OASIS submission requirement taking effect, ensuring accurate and quality documentation is now a top priority. Agencies should expect a higher volume of OASIS assessments, so having an efficient and consistent QA process in place is key. This not only supports compliance and survey readiness but also contributes to stronger quality reporting and HHVBP scores.
Key OASIS Exceptions to Keep in Mind
Some patients are exempt from OASIS data collection—regardless of payer:
- Under 18 years old
- Receiving maternity care
- Receiving only personal care, housekeeping, or chore services
- Seen for a single visit (per CMS quality episode guidance)
- Treated under loaned employee agreements
Compliance Requirements
To recall, OASIS applies to:
- All Medicare-certified HHAs, which must follow Medicare Conditions of Participation (CoPs)
- Medicaid providers in states that require compliance with Medicare CoPs
- If a patient is receiving skilled services (as defined by Medicare), and no exception applies, OASIS is mandatory, regardless of who pays for their care.
For more guidance on whether an OASIS required for certain complex situations, read through the April 2025 OASIS Q&As from CMS.
