FAQs

Question:

“I want to find the regulation information regarding uploading OASIS data to iQIES. Are Medicaid, Managed Medicaid, and Managed Medicare OASIS required to be uploaded at this time? I have not been able to find a regulation regarding this and have a client that is inquiring about this information. Please assist me with providing a regulation or guidance on the requirements for Michigan State guidance on uploading OASIS assessments.”  

I know that for now if M0150 is coded 1. Medicare (traditional fee-for-service); 2. Medicare (HMO/managed care/Advantage plan); 3. Medicaid (traditional fee-for-service); and 4. Medicaid (HMO/managed care), then the OASIS assessment must be submitted to the CMS. But in 2025 they may have to submit all of OASIS regardless of payer. 

Does anyone know where is the requirement that speak on this issue?

Answer:

State Operations Manual, Appendix B, page 31: 

§484.45 Condition of participation: Reporting OASIS information. 

G372

(Rev. 219; Issued: 04-12-24; Effective: 04-12-24; Implementation: 04-12-24) 

§484.45(a) Standard: Encoding and transmitting OASIS data. An HHA must encode and electronically transmit each completed OASIS assessment to the CMS system, regarding each beneficiary with respect to which information is required to be transmitted (as determined by the Secretary), within 30 days of completing the assessment of the beneficiary. 

(Page 32) An HHA must transmit a completed OASIS to the CMS system for all Medicare patients, Medicaid patients, and patients utilizing any federally funded health plan options that are part of the Medicare program (e.g., Medicare Advantage (MA) plans). An HHA must also transmit an OASIS assessment for all Medicaid patients receiving services under a waiver program receiving services subject to the Medicare Conditions of Participation as determined by the State. 

OASIS E Q&As: Reference Manuals 

CMS OASIS Q&As: CATEGORY 1 – APPLICABILITY 

Q1) To whom do the OASIS requirements apply? [Q&A EDITED 10/23; EDITED 05/22; EDITED 06/14 incorporating Previous CMS Qtrly 01/14 Q&A Q1]

A1) The comprehensive assessment and OASIS data collection requirements apply to Medicare-certified home health agencies (HHAs) and to Medicaid home health providers in States where those agencies are required to meet the Medicare Conditions of Participation. The comprehensive assessment requirement currently applies to all patients regardless of pay source, including Medicare, Medicaid, Medicare managed care (now known as Medicare Advantage), Medicaid managed care, and private pay/including commercial insurance. The comprehensive assessment must include OASIS items for all skilled Medicare, Medicaid, and Medicare or Medicaid managed care patients with the following exceptions: patients under the age of 18, patients receiving maternity services, patients receiving only personal care, housekeeping services, or chore services. Section 704 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 temporarily suspended OASIS data collection for non-Medicare and non-Medicaid patients. 

OASIS requirements for patients receiving only personal care, housekeeping, or chore services have been delayed since 1999. The transmission requirement currently applies to skilled Medicare and Medicaid patients only. 

If the care provided by the home health agency is billed to the Medicare Administrative Contractor (MAC) as traditional fee-for-service Medicare (M0150 - Current Payment Sources response 1) or billed to a State Medicaid Agency as traditional fee-for-service Medicaid (M0150 response 3), OASIS data collection is required. 

Likewise, if care provided by the home health agency is billed to an insurance company that has contracted with the Federal Agency (Medicare managed care - M0150 response 2) or State Medicaid Agency (Medicaid managed care - M0150 response 4), to pay for home health services with Federal Medicare or State Medicaid funds as a managed care plan, OASIS data collection is required. 

If care provided by the home health agency is billed to a non-insurance company entity (an organization coordinating and/or providing patient care services; or providing case management services; reported as M0150 response 6, 9, or 11), then OASIS data collection is not required, as funds, including those from Medicare/Medicaid sources, have been paid specifically to the non-insurer coordinating organization, and may not be specific to home health services. 

Note: When Medicare PPS (Patient Driven Grouping Model [PDGM]) is the payer for a patient otherwise excluded from the OASIS requirements (i.e., pediatric or maternity patients), the OASIS payment items must be collected in order to calculate a HIPPS code required for inclusion on the claim. While required for billing, the OASIS data for these excluded patients is not required to be submitted to the OASIS system.