Beginning July 1, 2025, OASIS data collection and submission will be mandatory for all patients regardless of payer, and home health agencies (HHAs) must be equipped to identify which patients are subject to this requirement.
In the April 2025 OASIS Q&As, CMS provided several clarifications to help agencies determine which patients require OASIS data collection. Let’s break them down in this article.
What Does “Regardless of Payer” Mean?
Many HHAs serve a wide range of patients—some covered by private insurance, others by community programs or self-pay, and some with no payer at all. The updated guidance clarifies that OASIS data collection and submission is required for all patients receiving skilled services, even if the care is not paid for by Medicare or Medicaid.
This includes patients whose care is:
- Paid by commercial insurance
- Funded by a charity or community waiver program
- Self-paid
- Provided without a payer
When Is OASIS Data Collection Required?
Based on the most recent CMS guidance, OASIS is required when:
- A Medicare-certified home health agency or a Medicaid provider (in states that follow Medicare’s Conditions of Participation) delivers more than one visit within a quality episode.
- The patient is receiving skilled services, as defined by Chapter 7 of the Medicare Benefit Policy Manual. (This manual is available on the CMS website).
When Is OASIS Data Collection Not Required?
OASIS is not required in the following situations:
- The patient is under the age of 18
- The patient is only receiving chore, housekeeping, or personal care services
- The patient is only receiving maternity services
- The HHA staff are contracted under a loaned employee agreement (e.g., with a pharmacy company) to provide services outside the scope of home health agency responsibilities
These exceptions were confirmed in the April 2025 CMS OASIS Quarterly Q&As and the November 2024 All-Payer Q&A document.
Preparing for July 1, 2025
As July 1 approaches, it is essential for HHAs to have a clear understanding of the updated OASIS requirements and accurately identify which patients require data collection. The all-payer mandate further emphasizes the need for OASIS compliance and reinforces the importance of maintaining high-quality, consistent care documentation across all payer types.
