CMS New Rule: All-Payer OASIS Data Collection and Submission required starting July 1st 2025
All-Payer OASIS Data Collection and Submission required starting July 1st 2025
Beginning July 1, 2025, all Medicare / Medicaid Certified home health agencies will be required to collect and submit OASIS data for all patients, regardless of their payer source. This includes patients with a Start of Care (SOC) M0090 date of July 1, 2025, or later.
This new rule states:
- 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. This means that any patient admitted on or after July 1st 2025 must have a SOC OASIS-E1 completed and submitted to the state.
- Include all subsequent OASIS time point assessments (resumption of care, recertification, other follow-up, transfer, discharge, and death at home).
- 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
Related fact sheet and Q&A document from CMS can be found in the following links:
FACT SHEET
Q&A
Getting ready in Igea:
It is important to understand that the OASIS data collection and submission for non-Medicare / Medicaid patients is NOT a requirement for billing. This means that in Igea the Pre-Billing report will not be validating or blocking the claim billing process for these payers if no OASIS has already been completed and submitted to the state (as it currently does for Medicare PDGM and FFS with HIPPS payer sources).
Though, a new Igea version will be released in June 2025 which will include the following features to help you tracking the OASIS creation for these payers:
- New Healthcare Plan setting to indicate if the payer requires OASIS data collection and submission.
Under Administration / Payer Sources / Other Settings a new checkbox setting willi be added:

This new setting will be automatically be set to = ON for all your payers in your system if you currently have at least 1 (one) invoice billed OR 1 (one) OASIS completed for any healthcare plan currently configured as any of the following Insurance Type:- Medicare OR
- Medicare hospice OR
- Medicare HMO OR
- Medicare Advantage / Managed Care
Note: the Insurance Type configuration can be located under Administration / Payer Sources / Billing Settings.
- If this new setting “OASIS required” is ON for a healthcare plan, when working in any of the Operations / Patient Services section, the patients and certification period grid will indicate if the OASIS for that patient / period is required or not, missing or has been already created:

The certification period’s OASIS requirement status can be:
- Not required: the healthcare plan does not require OASIS data collection and submission.
This status will be reported for any healthcare plan having the new setting “OASIS required” = OFF or for any healthcare plan having the setting = ON but the patient’s admission SOC date is prior to July 1st 2025.
- Missing: the OASIS data collection is required for the patient’s healthcare plan and period (based on the SOC Date of the patient), and the OASIS has not been created yet.
The system will validate if the SOC OASIS was created already for the initial certification period of the patient’s admission and will validate if the RECERT OASIS was created for each subsequent recertification period.
- Created: the OASIS data collection is required for the patient’s healthcare plan and period, and the OASIS has been already created (SOC or RECERT).
Note: for any PDGM or FFS with HIPPS Code healthcare plan, the OASIS Data collection will be always required in the system (regardless the new setting status).
Important: if you are a Medicare certified agency and provide services to non-medicare/Medicaid patients, you will need to update your healthcare plan’s service configuration to make sure the OASIS assessments (iPOC forms) are added as required in the applicable services.
A new MyIgea article will be published with steps on how to update / set up your services to accommodate to the new OASIS data collection requirement.
If you have any questions related to these features or need assistance, please contact our Customer Support Department with igea Chat or give us a call: 866-356-9167 or emal igea-support@Careficient.com
Igea Software (by Careficient)