OASIS-E2 is the latest version of the Outcome and Assessment Information Set, effective April 1, 2026. It replaces OASIS-E1 for all assessments completed on or after that date. While CMS calls it a "minor revision," there are meaningful changes that affect how you code, what you collect at Resumption of Care, and how skip patterns flow through the assessment.

I've been through OASIS version transitions before as a practicing OT. Here's everything that changed, why it matters, and exactly what you need to do differently — no CMS-speak, no paywalls.

What Determines Which Version You Use

The version you use depends on one date: M0090 (Date Assessment Completed). If M0090 is April 1, 2026 or later, you use OASIS-E2. If it's March 31 or earlier, you use OASIS-E1 — even if you started the assessment before April 1.

There is no grace period. This is a hard cutoff.

Warning

If you start an assessment on March 30 but complete it on April 2, that assessment uses OASIS-E2. The completion date is what matters, not the start date. Confirm with your EHR vendor that your system switched over on April 1.

Why This Is Off-Cycle

OASIS versions have historically aligned with January 1 calendar year starts. The April 1 date is unusual — it's an off-cycle implementation finalized in the CY 2026 HH PPS Final Rule. This caught many agencies off guard. CMS published the final guidance manual and updated Q&As on February 26, 2026, giving agencies about five weeks to prepare.

Every Item That Changed

There are nine specific changes in OASIS-E2. Here's each one in detail.

1. M0069 (Gender) Replaced by A0810 (Sex)

The item formerly known as M0069 "Gender" is now A0810 "Sex."

What changed:

Item number: M0069 is now A0810
Title: "Gender" is now "Sex"
Response options remain the same: 1 = Male, 2 = Female
The guidance phrase "If the patient does not self-identify" has been removed

How to code it: Code the patient's sex as recorded in their Medicare administrative data. This item is now strictly an administrative data point aligned with Social Security Administration standards, not a clinical assessment of gender identity.

Why it changed: CMS is standardizing this item across all post-acute care settings (home health, SNFs, IRFs). The change aligns home health data collection with the same item used in other Medicare programs.

Collected at: SOC, ROC, Follow-Up, Transfer, Discharge, Death at Home — same as before.

2. A1250 (Transportation) Replaced by A1255 (Transportation)

This is the biggest structural change in OASIS-E2. The old A1250 was completely replaced with a different item — not just renumbered.

Old A1250 (OASIS-E1):

Asked about the "past six months"
Multiple response codes: A (Yes), C (No), X (Unable to respond), Y (Declines to respond)
Collected at SOC, ROC, and Discharge

New A1255 (OASIS-E2):

Asks: "In the past 12 months, has lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?"
Timeframe expanded from 6 months to 12 months
Adds the word "reliable" before transportation
Adds "meetings, work" to the activities list
Completely new response codes:
- 0 = Yes
- 1 = No
- 7 = Patient declines to respond
- 8 = Patient unable to respond
- Dash = No information (rare)

Warning

A1255 is no longer collected at Discharge. It's SOC and ROC only. If your EHR still prompts for transportation at discharge, that's a software issue — contact your vendor.

Why it changed: Part of CMS's initiative to better track Social Determinants of Health (SDOH). The item is now aligned with the PRAPARE screening tool used in community health centers, enabling cross-setting data comparison.

3. B0200 (Hearing) Added to ROC

Previously collected at SOC only. Now collected at SOC and ROC.

Response options (unchanged):

0 = Adequate — no difficulty in normal conversation
1 = Minimal difficulty — difficulty in some environments (soft speech, noisy settings)
2 = Moderate difficulty — speaker must increase volume and speak distinctly
3 = Highly impaired — absence of useful hearing
Dash = No information

Why it was added to ROC: A patient returning from an inpatient stay may have experienced hearing changes due to stroke, medication changes, or other events during hospitalization. Reassessing at ROC captures these changes for accurate risk-adjustment of quality measures.

4. B1000 (Vision) Added to ROC

Previously collected at SOC only. Now collected at SOC and ROC.

Response options (unchanged):

0 = Adequate — sees fine detail, regular print
1 = Impaired — sees large print but not regular print
2 = Moderately impaired — limited vision, can identify objects but not headlines
3 = Highly impaired — object identification in question, eyes appear to follow objects
4 = Severely impaired — no vision or sees only light, colors, shapes

Same rationale as hearing: Post-hospitalization vision changes (surgical complications, medication effects, stroke) need to be captured at the start of the new quality episode.

5. A1110 (Language) Added to ROC

Previously collected at SOC only. Now collected at SOC and ROC.

This is a two-part item:

Part A: "What is your preferred language?" (15 language options including English, Spanish, Chinese, Vietnamese, Tagalog, and more)
Part B: "Do you need or want an interpreter to communicate with a doctor or health care staff?" (Yes/No)

The response-specific instructions were also updated: "Complete as close to the time of SOC or ROC as possible."

Why it matters: Language preference affects care coordination, and a patient's communication needs may change after a hospitalization — particularly after neurological events that affect speech or comprehension.

6. D0150 (PHQ-2 to PHQ-9) — Dash Now Allowed for Frequency

In OASIS-E1, Column 2 (Symptom Frequency) of D0150 did not allow a dash response. In OASIS-E2, it does.

What this means: If a patient reports having a symptom (Column 1 = Yes) but you truly cannot determine the frequency, you can now enter a dash in Column 2 instead of being forced to pick a frequency or mark the interview incomplete.

The PHQ frequency scale remains:

0 = Not at all (0 days)
1 = Several days (2-6 days out of past 14)
2 = More than half the days (7-11 days)
3 = Nearly every day (12-14 days)
Dash = Unable to determine frequency (new in E2)

Tip

CMS explicitly states they expect dash use to be rare. Don't use this as a shortcut. It's for genuine situations where the patient confirms having a symptom but cannot provide any frequency information — for example, a patient with cognitive impairment who can identify symptom presence but not frequency.

Impact on D0160 (Total Severity Score): The scoring rules for D0160 were updated to account for dashes. Items in Column 2 that are "skipped or dashed" are handled the same way — omitted from the sum calculation. If 3 or more Column 2 items are blank or dashed, the interview is deemed incomplete.

7. O0350 (COVID-19 Vaccination) Removed

The COVID-19 vaccination status item has been entirely removed from OASIS-E2. The associated quality measure "COVID-19 Vaccine: Percent of Patients Up to Date" was finalized for removal from the HH QRP in the CY 2024 Final Rule, with final public reporting in January 2026.

What to do: Nothing — your EHR should simply no longer present this item. If it still appears, that's a vendor issue.

8. SDOH Items (R0310, R0320A, R0320B, R0330) Removed

Four Social Determinants of Health items — Living Situation, Food (ran out), Food (worried about running out), and Utilities — were finalized for removal. These items were approved but never actually implemented in any OASIS version. CMS removed them before they went live.

What to do: Nothing. You were never required to collect these.

9. J1800/J1900 (Falls) — Expanded Guidance

The falls items themselves didn't change structurally, but the guidance was significantly expanded:

J1800 (Any Falls Since SOC/ROC):

Now explicitly includes falls outside the home
Now explicitly includes falls caused by external forces (tripping, being bumped)
Any unintentional change in position where the patient ends up on the floor/ground counts

J1900 (Number of Falls Since SOC/ROC):

Response B revised to: "Injury (except major) — per OASIS manual definition"
Response C revised to: "Major Injury — per OASIS manual definition"

Major injuries include: traumatic bone fractures, joint dislocations/subluxations, internal organ injuries, amputations, spinal cord injuries, head injuries, crush injuries.

Not major injuries: pathological fractures, skin tears, abrasions, lacerations, superficial bruises, hematomas, sprains, fall-related pain.

50%+of falls with major injury identified via claims data were NOT reported on OASIS assessments, per CMS analysis

This is the single most scrutinized OASIS area right now. CMS is working on a respecified Falls with Major Injury measure that cross-references claims data with OASIS reporting. Underreporting falls will increasingly trigger audits and hurt your quality scores.

Skip Pattern Changes You Need to Know

Three skip patterns changed in OASIS-E2. If you've memorized the old assessment flow, update your mental model.

M0102 Skip Pattern

Old: Skip to A1250 (Transportation)
New: Skip to A1255 (Transportation)
This is just a reference update for the item replacement.

M1000 Skip Pattern (ROC Assessments)

Old: If NA (not discharged from inpatient facility) → Skip to B1300 (Health Literacy)
New: If NA → Skip to B0200 (Hearing)

This is the functionally significant change. The new sensory items (B0200 Hearing, B1000 Vision) are inserted before B1300 Health Literacy in the ROC flow. If you're on autopilot with the old sequence, you'll skip hearing and vision entirely.

A1255 at Discharge

A1255 is no longer collected at Discharge. If your old workflow included A1250 at discharge, remove that step.

What Changed in Chapter 1 (Administrative Guidance)

CMS significantly expanded the administrative sections of the OASIS manual. These don't change how you score items, but they affect agency operations.

All-Payer OASIS Is Now Mandatory

As of July 1, 2025, OASIS is required for every skilled patient regardless of payer — Medicare, Medicaid, Medicare Advantage, commercial insurance, and self-pay. OASIS-E2 applies to all of them.

Four conditions must all be met:

Any pay source
Receiving skilled services
Not exempt from OASIS data collection
Home health care services with SOC M0090 date on or after July 1, 2025

Info

Exception: Outpatient therapy services (PT, OT, SLP) provided by an HHA and billed under Medicare Part B that do not have a home plan of care in effect do not require OASIS completion.

Payer Source Changes (New Section 1.5.2.3)

CMS added detailed guidance on what to do when a patient's payer changes mid-episode:

Any payer to different payer: CMS recommends discharge from previous pay source and new SOC OASIS under new pay source
Medicare FFS to Medicare Advantage: Medicare does NOT require a new SOC
Medicare Advantage to Medicare FFS: A new SOC OASIS IS required
Skilled to non-skilled (e.g., personal care only): CMS encourages but does not require a discharge OASIS at the last skilled visit

Software Cannot Auto-Complete OASIS (Convention #9)

CMS added a new convention explicitly stating that agency software may not "answer" or "generate" OASIS responses for the assessing clinician. AI tools can assist with quality review, provide guidance, and flag potential errors — but every response must be entered by the clinician.

Unplanned Discharge Guidance (Convention #10)

New detailed guidance for unplanned discharges, including how to handle items in the "last 5 days" assessment window and when to use dashes for items where patient interview is not possible (BIMS, PHQ-2 to 9).

Impact on Payment (PDGM)

The OASIS-E2 item changes themselves do not directly alter PDGM grouping logic or case-mix weights. You won't see a payment change solely from the E1-to-E2 transition.

However, the CY 2026 Final Rule includes significant PDGM recalibration that took effect January 1, 2026:

Component	Impact
Base payment update	+2.4% increase
Permanent prospective adjustment	-1.023%
Temporary one-year adjustment	-3.0%
Net aggregate impact	-1.3% decrease ($220M reduction)

Case-mix weights were recalibrated using CY 2024 claims data. LUPA thresholds were updated. Functional impairment levels were recalibrated. This means accurate GG scoring is more impactful than ever — the weights more precisely tie payment to functional status.

Warning

Inconsistent functional scoring across clinicians is cited as the most frequent OASIS error triggering Requests for Information (RFIs) and claim denials. With recalibrated weights, inaccurate GG scores cost you more than they used to.

Impact on Quality Measures and Star Ratings

Directly Affected Measures

Measure	What Changed
COVID-19 Vaccination	Withdrawn entirely from HH QRP
Falls with Major Injury	J1800/J1900 expanded guidance will likely increase reported falls. CMS is developing a respecified version cross-referencing claims + OASIS data.
Discharge Function Score	GG item Discharge Goal columns being removed — CMS will use an algorithm instead of clinician-set goals

HHVBP 2026 Updates

CY 2026 is the second payment year of the expanded Home Health Value-Based Purchasing model. Agencies can see up to 5% upward or downward payment adjustments.

New HHVBP measures for 2026:

Improvement in Bathing (M1830)
Improvement in Upper-Body Dressing (M1810)
Improvement in Lower-Body Dressing (M1820)
Medicare Spending per Beneficiary-PAC (claims-based)

Category weights:

OASIS-based measures: 40%
Claims-based measures: 40%
HHCAHPS measures: 20%

With all-payer OASIS now mandatory, outcome calculations include all patients, not just Medicare. This could shift your Star Rating scores as non-Medicare patient outcomes enter the mix.

The 8 Things You Need to Do Differently

Here's your actionable checklist — what actually changes in your day-to-day documentation practice.

1. Update Your ROC Workflow

Add three items to every Resumption of Care assessment:

B0200 — Hearing
B1000 — Vision
A1110 — Language (preferred language + interpreter need)

These come before B1300 (Health Literacy) in the assessment sequence. If your EHR vendor hasn't updated the flow, flag it immediately.

2. Use A1255 for Transportation (Not A1250)

Single-select format (not check-all-that-apply like the old A1250)
New response codes: 0 = Yes, 1 = No, 7 = Declines, 8 = Unable
12-month lookback (not 6 months)
Not collected at Discharge anymore

3. Code A0810 (Sex) From Administrative Records

Code based on Medicare/administrative data, not patient self-identification
The old "If the patient does not self-identify" guidance no longer exists
Response options remain 1 = Male, 2 = Female

4. Ask About ALL Falls — Including Outside the Home

Falls outside the home count
Falls caused by external forces (tripping, being bumped) count
Classify injuries using the updated definitions — pathological fractures are not major injuries
Document every fall since SOC/ROC, no exceptions

5. Use the D0150 Dash Sparingly

Dash is now valid for PHQ frequency items (Column 2) but is expected to be rare
Only use when the patient confirms a symptom but genuinely cannot report frequency
Three or more dashed/blank Column 2 items = interview incomplete

6. Remove O0350 From Your Process

COVID-19 vaccination item is gone
Remove it from any internal checklists, QA reviews, or assessment templates

7. Standardize GG Scoring Across Your Team

Recalibrated case-mix weights make inconsistent functional scoring more costly
Ensure all clinicians use the same methodology for GG0130 (Self-Care) and GG0170 (Mobility)
A clinician's presence for the assessment should not automatically be coded as "supervision" level assistance

8. Collect OASIS for Every Skilled Patient

All-payer mandate is in effect since July 1, 2025
Same items, same rigor for Medicare, Medicaid, MA, commercial, and self-pay patients
Voluntary OASIS data will NOT be used for quality measures, star ratings, or HHVBP

Summary of All OASIS-E2 Changes

Change	Old (E1)	New (E2)	Time Points
Gender/Sex	M0069 Gender	A0810 Sex	All
Transportation	A1250 (6mo, multi-select)	A1255 (12mo, single-select)	SOC, ROC only
Hearing at ROC	SOC only	SOC + ROC	SOC, ROC
Vision at ROC	SOC only	SOC + ROC	SOC, ROC
Language at ROC	SOC only	SOC + ROC	SOC, ROC
PHQ Frequency dash	Not allowed	Allowed (rare)	SOC, ROC, FU, DC
COVID-19 Vaccine	O0350 collected	Removed	N/A
SDOH items	Approved, never used	Removed	N/A
Falls guidance	Basic	Expanded (outside home, external forces)	SOC, ROC, FU, DC

Training Resources

Official CMS Resources

OASIS-E2 Guidance Manual — The 344-page source of truth, includes Appendix D (change table)
OASIS-E2 Q&As — 50+ revised Q&As covering common scenarios
OASIS-E2 Change Table — Standalone 40+ page PDF showing every change
OASIS-E2 Data Sets — All Items and Time Point versions
CMS Quality Reporting Training — Virtual training program
CMS Home Health Quality Helpdesk: HomeHealthQualityQuestions@cms.hhs.gov

Industry Resources

OASIS Answers — Free E1-to-E2 overview articles, paid Blueprint for OASIS Accuracy workshops
MedBridge — Free OASIS-E2 change table download, cheat sheet, and microlearning courses
SHP — Free color-coded OASIS-E1 to E2 Crosswalk Guide (printable)

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