Preparing for CMS’s All-Payer OASIS Requirement

A 30-Day Countdown Guide for Home-Health Leaders

Beginning July 1, 2025, every Medicare-certified home-health agency (HHA) must collect and transmit an OASIS assessment on every patient—regardless of payer. Below is a concise, professional roadmap you can share with executives, clinicians, and compliance staff.

1. What Is Changing?

CURRENT RULE (THROUGH JUNE 30)	NEW RULE (EFFECTIVE JULY 1)
OASIS required only for Medicare and Medicaid patients	OASIS required for all patients
Voluntary phase-in: January 1 – June 30, 2025	Mandatory compliance: Assessments with an M0090 date on or after July 1, 2025, must be submitted to iQIES within 30 days
Still excluded: Patients under 18, maternity-only cases, and chore/housekeeping-only services	No changes to exclusions

2. Why the Change Matters

PURPOSE	OPERATIONAL CONSEQUENCES
Broader quality lens	CMS will benchmark outcomes across all payer types, potentially exposing overlooked clinical or operational gaps.
Future payment design	CMS has signaled that all-payer data may support future iterations of Home-Health Value-Based Purchasing (HHVBP) and other models.
Compliance risk	Late or missing files can reduce your Annual Payment Update (APU) by up to 2 percentage points and draw survey citations.

3. Required OASIS Time Points (Unchanged)

Start-of-Care (SOC)
Resumption-of-Care (ROC)
Recertification / Other Follow-Up
Transfer (with or without discharge)
Discharge from agency
Death at home

4. 30-Day Action Plan

TIMELINE	PRIORITY TASK	PRACTICAL TIPS
Week 1	Validate systems	Remove any “payer-type” gate in your EMR; build a private-insurance test chart and transmit to iQIES.
Week 2	Targeted staff refreshers	Host brief huddles on key OASIS-E items and the April 2025 CMS Q&As; circulate printed cheat-sheets.
Week 3	Policy & paperwork update	Retire “Attachment C.” Provide only the CMS Privacy Act Statement plus Attachment A moving forward.
Week 4	Dry-run submissions	Select five active non-Medicare cases; complete the appropriate OASIS time point within 48 hours and submit. File the iQIES validation reports in a survey-ready folder.

5. Common Problem Spots—and Quick Fixes

ISSUE	MITIGATION
EMR still blocks OASIS for commercial payers	Work with your vendor to disable any payer filter; verify test uploads before July 1.
Clinicians omit functional items on therapy-only episodes	Embed prompts in visit notes and reinforce that therapy-only does not waive OASIS.
Separate payer-specific assessments create duplication	Map a dual-workflow: complete the payer form at the visit, then populate the OASIS in the office to ensure consistency.

6. Key Reminders for Your Team

OASIS is a comprehensive assessment, not just a billing tool.
Every data element must represent the patient’s status within the 48-hour assessment window.
Keep electronic copies of each final validation report as proof of on-time submission.
Subscribe to the Home-Health QRP Spotlight emails for late-breaking technical guidance.

7. Recommended Resources

CMS All-Payer Transition Fact Sheet (Dec 2024) – high-level summary. cms.gov
CMS All-Payer OASIS Q&As (Nov 2024 & Apr 2025) – detailed scenarios and coding guidance. cms.govqtso.cms.gov
CY 2025 Home-Health Final Rule Overviews – payment and HHVBP context. thehomehealthconsultant.com

Conclusion

A smooth go-live on July 1, 2025 rests on the groundwork you lay today. Validate your software, upskill your team, and pressure-test every workflow in June; nail those steps now, and the rest of the year can be spent on patient care, not on scrambling to fix data errors.

Cliniqon supports HHAs in navigating CMS’s All-Payer OASIS requirement by providing expert clinical guidance, OASIS-E refresher training, and thorough QA oversight. We help ensure OASIS assessments for all payer types are accurately completed and submitted on time to avoid documentation errors, survey risks, and APU penalties. Our team offers targeted education using CMS resources, quick-reference tools, and case-based review sessions to strengthen staff competency. We also assist agencies in preparing for dry-run assessments, analyzing validation reports, and reinforcing compliance with required OASIS time points. Post-implementation, Cliniqon continues to provide consultative support, coding accuracy reviews, and performance insights to help agencies stay compliant and prepare for future value-based models using all-payer data.