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Proposed Rule: OASIS Reporting Required for All Payers in 2025

    On June 26, CMS released the 2025 Home Health Proposed Rule. Among the changes are updates to OASIS requirements that will become mandatory in 2025.

    To recall, the 2023 Home Health Final Rule established that, starting in 2025, home health agencies must complete and transmit OASIS for 100% of their patients, regardless of payer. This aims to standardize data collection across all patients. 

    Skilled nursing facilities have long been required to report all patients regardless of payer. This requirement is now being extended to home health agencies to ensure fair comparisons and accurate outcome assessments.

    The 2025 Home Health Proposed Rule introduces a transitional period for this requirement. This phased approach allows home health agencies to gradually adapt to the new reporting standards.

    • Voluntary Reporting: Starts January 1, 2025.
    • Mandatory Reporting: Starts July 1, 2025.

    The SOC is the first assessment that can be submitted for a non-Medicare/non-Medicaid patient.

    Impact on Outcome Calculations

    Starting July 1, 2025, all payers will be included in outcome calculations. This includes Medicare, Medicare Advantage, skilled Medicaid, and other payers. The inclusion of ALL payers is designed to provide a comprehensive assessment of patient outcomes across the post-acute care continuum.

    There will be risk adjustments and allowances based on specific patient information and payer situations. These factors will influence outcome calculations, affecting both star ratings and value-based purchasing outcomes.

    Emphasis on Accuracy

    Accurate and thorough OASIS assessment has become more crucial for all patients, not just those under Medicare and Medicare Advantage. If your agency currently follows relaxed documentation standards for private insurance, it is time to enhance these practices and start implementing Medicare’s standards uniformly as early as now.  Reporting of all OASIS from all payers will be essential for compliance and for obtaining accurate outcome calculations.

    Home health agencies should prepare for these changes to ensure a smooth transition and compliance with the new requirements.