The Centers for Medicare & Medicaid Services (CMS) is rolling out significant changes for home health agencies (HHAs) regarding OASIS data collection and submission. These changes, which apply to all payers, mark an essential shift in how agencies will document and report patient care. Here’s what you need to know to stay ahead.

Timeline for Compliance 

  • January 1, 2025: HHAs can begin voluntarily collecting and submitting OASIS data for all patients, regardless of payer. 
  • July 1, 2025: Submission of OASIS data becomes mandatory for all payers. 

Updated Privacy Notice Required from January 1, 2025 (regardless of when your agency begins implementation of the All-Payer initiative) 

Effective January 1, 2025, agencies must update the privacy documents provided to patients, regardless of their payer source. This includes: 

  • START providing Attachment A: Statement of Patient Privacy Rights and the Privacy Act Statement – Health Care Records to all patients, regardless of payor source. 
  • STOP providing Attachment C to non-Medicare and non-Medicaid patients. 

The documents are available on the CMS Home Health Agency Center in English and Spanish.  

Key FAQs for Agencies 

  1. Why is CMS collecting all-payer OASIS data? CMS aims to gain a holistic understanding of care quality across all patients served by Medicare-certified HHAs, irrespective of payer source. This data could influence future quality and payment policies.
  2. Will the all-payer data be used in the HHVBP Model? Currently, CMS has not determined if or how non-Medicare/Medicaid OASIS data will impact the expanded HHVBP Model. Updates will be communicated via the HHVBP Model webpage.
  3. Which patients are exempt from OASIS data collection? The exemptions remain unchanged: 
    • Patients under 18.
    • Patients receiving only maternity care.
    • Patients receiving only personal care, housekeeping or chore services.
    • Patients with single-visit quality episodes.
  4. How should agencies handle patients with care episodes spanning January 1, 2025? For patients with OASIS data collected before January 1, 2025, submissions for non-Medicare/Medicaid patients should not be made in the iQIES system.

What about charity or no pay patients?

OASIS data collection is required for all payer types, including no-pay, when more than one visit occurs, provided the agency is Medicare-certified. The key here is “when more than one visit occurs.” Often when charity patients are referred, only one visit is ordered. OASIS is not required when only a single in-person visit is made in a quality episode. OASIS data collection at discharge should not be collected or submitted in situations of a single in-person visit in a quality episode. It is essential that agencies plan ahead for the efficient care of no pay patients and not burden staff with additional OASIS assessments that are not required. 

Recommendations for Agencies 

  • Begin training staff on the updated privacy notice requirements and data collection processes for all-payer OASIS. 
  • Consider the education needs of staff who will complete the OASIS on increased numbers of patients.  
  • Prepare to integrate all-payer OASIS data collection into your workflow starting January 1, 2025, even though submissions won’t be mandatory until July. 
  • Plan for monitoring of the quality of the OASIS collected prior to transmission. 
  • Stay informed on how all-payer data may impact quality measures and reimbursement models. 

Transitioning to the all-payer OASIS requirement presents challenges, but early preparation will position your agency for success. By aligning your practices with the updated CMS guidance, you can ensure compliance while continuing to provide high-quality care to your patients. 

Lisa Selman-Holman, JD, BSN, RN, HCS-D, COS-C Vice President, Education & Quality

About the Author

Lisa Selman-Holman, JD, BSN, RN, HCS-D, COS-C, VP of Education and Quality

Lisa Selman-Holman, JD, BSN, RN, HCS-D, COS-C, is the VP of Education & Quality at McBee, bringing over 35 years of expertise in home health and hospice. As a registered nurse and home care attorney, she specializes in regulatory compliance. Lisa has held various roles, from field nurse to executive, managing accreditation surveys, acquisitions, and regulatory crises. In 2004, she founded Selman-Holman & Associates, offering consulting, coding and OASIS review services. Lisa is a renowned educator, known for turning challenges into achievements. Joining McBee in 2021, she leads education initiatives at the Post-Acute Academy, providing courses for home health and hospice staff and executives, including clinical, regulatory and onboarding requirements.

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