The U.S. Centers for Medicare & Medicaid Services (CMS) has laid out an action items timeline for the transition to all-payer Outcome and Assessment Information Set (OASIS) data collection and submission. The all-payer OASIS data requirement is set to begin in 2027.

Broadly, home health providers will be required to collect and submit OASIS data for more patients. This means non-Medicare and non-Medicaid payer sources, as well as individuals who self-pay.

“CMS expects to use this all-payer data to gain a better understanding of the overall quality of care provided by Medicare-certified [home health agencies] to the patients they serve, regardless of payer source,” CMS wrote in a fact sheet. “CMS will monitor the all-payer OASIS data and will notify providers when decisions are made for future uses for quality or payment purposes.” 

CMS noted that home health providers will need to update their workflows to meet the new data submission requirements. The federal agency also pointed out that providers may need to revamp training efforts to make sure that their staff are prepared for the changes. 

One of the first action items that CMS highlighted for providers on Jan. 1 2025 is the validation of their understanding of the new requirements. This means gathering and submitting OASIS data for all skilled Medicare and Medicaid patients. It also means verifying any requirements to turn in OASIS data to other entities for excluded patients, according to the fact sheet.

From Jan. 1 to June 30, 2025, providers keep up OASIS data collection and submission for all skilled Medicare and Medicaid patients. They should also collect and submit voluntary all-payer OASIS data during this time period. They should also stay on top of exclusions.

“Continue to exclude patients under the age of 18, those receiving maternity services, and those receiving only personal care, housekeeping, and/or chore services from OASIS data collection and submission requirements,” CMS wrote.

Starting July 1, 2025, providers should be collecting and submitting mandatory OASIS data.

“Collect and submit OASIS data for all patients with any pay source who are not exempt from OASIS data collection and who begin receiving home health care services with an OASIS SOC M0090 date on or after July 1, 2025,” CMS wrote. “Include all subsequent OASIS time point assessments.” 

During this time, providers should also continue exclusions, according to the fact sheet.

In addition to the transition timeline, CMS also announced that it will offer an online training course for individuals new to home health quality reporting program.