On July 1, 2025 the Centers for Medicare & Medicaid Services (CMS) quietly flipped a switch that affects nearly every Medicare-certified home health agency in the country. From that date forward, Outcome and Assessment Information Set (OASIS) assessments must be completed and submitted for every patient you serve, no matter who pays the bill.
That single line carries serious operational and compliance implications, so let’s break it down.
Who must submit OASIS now?
If your agency holds a Medicare certification, you are required to perform and file OASIS assessments for patients covered by:
- Veterans Affairs (VA)
- Medicaid
- Private pay
- Commercial insurance
It no longer matters that Medicare is not footing the bill; CMS wants a uniform data set across payers to compare quality, outcomes, and costs.
Who is not affected?
- Non-Medicare-certified agencies – nothing changes for you today.
- Agencies providing only a single visit – a one-off visit, without a full episode of care, is exempt.
Why CMS made the change
CMS is pushing for apples-to-apples data on patient outcomes across the entire home-health landscape. Uniform OASIS reporting:
- Creates consistent quality benchmarks,
- Flags clinical variations earlier, and
- Reduces reimbursement errors tied to incomplete documentation.
The upside is better insight into nationwide care quality. The downside is extra administrative lift for certified agencies that historically served mixed payer populations.
What to do next
- Already Medicare-certified:
- Audit your workflows. Make sure clinicians and back-office teams capture OASIS for every payer, enter it in your EMR or AMS, and transmit on schedule.
- Not Medicare-certified:
- No OASIS requirements apply today; keep your current documentation process.
- In the process of certification:
- Begin training staff on OASIS terminology, timelines, and submission procedures now so everyone is ready on Day 1 of certification.
For the official language straight from CMS:
- Transition to All-Payer OASIS Data Collection and Submission
- July 2025 CMS Quarterly OASIS Q&As
- OASIS User Manuals | CMS
