Mandatory “All-Payer” OASIS Changes Effective 7/1/25
As of July 1, 2025, every qualified home health patient—regardless of payer—must have a complete OASIS assessment reported. Exclusions remain unchanged. This update represents a shift toward more inclusive data that will likely impact quality scores, reimbursement, and competitive standing. The key OASIS changes effective July 1, 2025, for home health, as part of CMS’s Calendar Year (CY) 2025 Home Health rule include:
Mandatory “All-Payer” OASIS Data Submission
- Effective July 1, 2025: All home health patients with a Start of Care (SOC M0090) on or after this date must have OASIS assessments collected and submitted—regardless of payer source (Medicare, Medicaid, private insurance, self-pay)—unless exempt (e.g., age < 18, maternity-only, only personal care/housekeeping/chore services)
- SOC and all follow-ups must be submitted: resumption of care, recertification, transfer, discharge, and death at home.
Transition Guidance & Exclusions
- For non-Medicare/non-Medicaid patients with a SOC between Jan 1–Jun 30, 2025, agencies may voluntarily collect and submit an OASIS, but aren’t required to complete subsequent assessments—even if they occur after July 1.
- Patients that meet the following criteria are excluded from both voluntary and mandatory requirements:
- Under age 18
- Receiving maternity-only services
- Receiving only personal care, housekeeping, or chore services
Systems, Workflow & Staffing Implications
- Agencies must:
- Update OASIS forms (SOC, recertification, transfer, discharge).
- Ensure EHR and submission platforms (like iQIES) are configured for all-payer data, including updated M0150 payer selection logic
- Train clinicians and office staff on all-payer OASIS completion, focusing on accuracy, Section GG, and new format (OASIS-E1 for SOC M0090 ≥ Jan 1, 2025)
- Agencies must:
Impact on Quality Reporting & Value-Based Purchasing
- All-payer submissions will feed into the Home Health Quality Reporting Program (HH QRP) starting CY 2027, and influence performance outcomes (quality star ratings, HH Value-Based Purchasing).
- Data inclusion now mirrors skilled nursing facilities to improve fairness and make outcome comparisons more comprehensive.
If you have questions or concerns related to the upcoming OASIS changes, contact Proactive today for support.
Written By:
Nichole McClain, RN
Principal Consultant of Home Health Services
Proactive Medical Review
Contact Proactive to learn more about Five-Star Improvement support services and develop a road map to Five-Star success in 2025.