As of July 1, home health organizations must collect and submit Outcome and Assessment Information Set (OASIS) data for all patients served under a Medicare-certified organization, regardless of the payer source.
This mandate includes patients covered by non-Medicare, non-Medicaid, private insurance, self-pay and charity care. For many organizations, this change marks a significant shift in data collection practices and introduces a new layer of compliance and operational complexity.
Arlene Maxim, Senior Vice President of Clinical Services at Axxess, discussed the changes and explained the potential risks, benefits and implications for organizations.
What is Changing
Until now, OASIS was primarily required for Medicare and Medicaid patients. This change expands to all patients served by a Medicare-certified organization, regardless of insurer reimbursement.
“Every single patient that’s seen under the Medicare-certified program, including Medicaid, private pay, and even charity care, must have OASIS data collected and submitted into iQIES,” said Maxim.
This means that patients without a payment source and those receiving care as a charitable service must now be fully assessed and reported using the same standards as Medicare patients.
The goal is to ensure equitable care for all patients and consistent standards for all organizations.
What Organizations Need to Do
Prepare for Survey Risks: Surveyors now have the authority to review all patient records, including private pay and insurance cases. Organizations without documentation practices for non-Medicare patients may be subject to citations.
“This will be a condition-level citation and maybe even immediate jeopardy,” Maxim explained. “We’re talking fines of up to $25,597 a day.”
Review and Update Documentation Standards: Ensure consistent documentation quality for all payer types, not just Medicare. This includes visit notes, plans of care and patient rights notices.
Budget for Operational Changes: OASIS assessments require more time, which often means more pay. Organizations should account for increased staffing costs, training and system updates.
“They [organizations] are going to have to pay their staff more,” Maxim said. “There’s a financial impact here and it should’ve been built into the budget.”
Why it Matters
This change is fundamental to the future of value-based care and compliance.
“CMS wants to make sure that no matter how the care is being paid for, the same information is collected,” emphasized Maxim. “They [CMS] want to understand how social determinants of health impact care and ensure those patients get the resources they need.”
The data will be used in reports by the Centers for Medicare and Medicaid Services (CMS) to inform national health equity efforts.
“This isn’t just about filling out more forms,” said Maxim. “It’s about ensuring care is consistent, equitable, and accountable, no matter the payment source.”
Axxess Home Health, a cloud-based home health software, empowers healthcare organizations with a chart of accounts feature and a suite of detailed financial reports, streamlining data collection and facilitating seamless financial operations.