Home Health OASIS Submission Requirements for All Patients, HHQRP Resources
Effective January 1, 2025, home health agencies could voluntarily begin submitting OASIS data for all patients regardless of payer. The collection and submission of the OASIS for all patients becomes mandatory July 1, 2025.
The Centers for Medicare & Medicaid Services (CMS) removed the temporary suspension of the OASIS data collection on non-Medicare/non-Medicaid home health agency patients through the CY2023 Home Health Prospective Payment System Rate Update final rule and updated the removal in the CY2025 Home Health Prospective Payment System Rate Update final rule. With these changes, patients who have received home care services of more than one visit in a quality episode provided by all Medicare-certified home health agencies and Medicaid home health providers in states where those agencies are required to meet the Medicare Home Health Conditions of Participation, are eligible for OASIS data collection and submission.
There are no changes to patients excluded which are those under the age of 18, those receiving only maternity services, and those receiving only chore, housekeeping or personal care services. As stated above, there is a voluntary period prior to the mandatory implementation date of July 1, 2025.
There are many questions about the revised requirement which CMS has addressed in a Q&A document. CMS has also released a Fact Sheet and provided guidance on the provision of the OASIS privacy notice. Specifically, effective January 1, 2025 HHAs should only provide patients with the CMS Privacy Act Statement and Attachment A – Statement of Patient Privacy Rights. Attachment C – Notice About Privacy for Patients Who Don’t Have Medicare or Medicaid should not be provided to patients. These forms are available on the Home Health Agency Center webpage in the OASIS section. Both documents are available in English and Spanish.
In addition to these OASIS resources, CMS has also posted updated introductory courses to the Home Health Quality Reporting Program (HHQRP). This series of courses is helpful for those new to the HHQRP as well as those interested in a refresher.
