Q and A

Category 1:

Q1) Our agency has successfully submitted several Start of Care (SOC) OASIS assessments for some of our commercially insured patients. We do not plan on continuing to practice data collection and submission for the remainder of the phase in time. Starting on July 1st, we plan on collecting and submitting OASIS on all patients, even if the patient was active before July 1st, 2025. This would mean that the first OASIS assessments submitted for some patients may be a recertification, or a discharge, etc. Will such assessments be rejected by iQIES if there is no SOC in the system? What indicator(s) will CMS be using to identify these assessments so that their OASIS information doesn’t impact our surveys or Total Performance score (TPS) for the expanded HHVBP Model? 

Q2) Our agency has been completing and submitting OASIS for our non-Medicare/non-Medicaid patients as of January 1st. We assume that CMS is not using the data submitted during this voluntary phase, but what will happen after the voluntary phase is over? If we continue to submit OASIS on patients who started care in the voluntary phase but are still active into July, is CMS going to use that patient’s data for any quality measures or in the measure calculation for the HHVBP measures? And is there any case in which CMS would end up using a patient’s data from the voluntary phase? 

Category 2:

Q3) Our home health agency provides services (fills a Medi-Plan and provides monthly supervision to a home health aide) to patients under a Medicaid program. While these patients meet the payment requirements under the Medicaid program, these types of services would not meet the definition of “skilled care” under the Medicare home health benefit. Should OASIS data be collected and submitted for these patients? 

Q4) If we admit a non-Medicare/non-Medicaid patient with a Start of Care (SOC) date of June 29th, 2025, but don’t finish their SOC comprehensive assessment until on or after July 1, 2025, are we required to collect and submit an OASIS? 

Q5) If a non-Medicare/non-Medicaid patient is admitted in February 2025, has a qualifying inpatient stay in June 2025, resumes care in July 2025, and remains on service until October 2025, will the collection/submission of any OASIS assessments be required? 

Q6) If our home health agency is contracted to provide staff to another company (for example, our agency provides a nurse to manage PICC line dressing changes and/or draw labs for a pharmacy company), is OASIS data collection and submission required? 

Q7) If a patient’s pay source changes from Medicare Advantage to Medicare FFS while the patient is on services with a home health agency and OT is the only active discipline, are they allowed to complete the SOC comprehensive assessment including OASIS, even though the need for occupational therapy does not establish program eligibility under the home health benefit? 

Q8) How should the OASIS items be completed when there is an unplanned discharge and specific items were not assessed within the look-back period? 

Category 4b

Item M0150

Q9) We have patients with Medicaid coverage residing in an Assisted Living Program (ALP) or involved with a PACE program. Home care services are reimbursed directly from the ALP or from the PACE program, and our agency is not billing Medicaid for these services while a patient is a participant in these programs. How should M0150 - Current Payment Sources for Home Care be coded?  

Q10) We have patients who are receiving home care services under UHC Dual Complete, a combined Medicare and Medicaid managed care insurance payer. For M0150 - Current Payment Sources for Home Care, should both response 2 - Medicare (HMO/managed care) and 4 - Medicaid (HMO/managed care) be checked, or should only one be checked since we are billing a single payer (UHC Dual Complete)? 

J0510-J0530 

Q11) If a pain interview is conducted at the time of the start of care (SOC) visit and J0150- J0530 - Pain interview is coded based on the patient’s responses at that time, can we update the responses to the applicable pain items, if the patient’s status changes during the assessment timeframe?