OASIS-E2 Post-Deadline Compliance Checklist: What CMS Just Clarified

OASIS-E2 has been live since April 1, 2026. On April 21, CMS published its first OASIS Quarterly Q&A of the new version — 14 clarifications that answer the questions agencies started raising the moment the new manual hit. Some confirm what the manual already said. Others materially change how you should be coding, training your staff, and configuring your software right now.

This post is the post-deadline compliance checklist, sourced entirely from CMS — the OASIS-E2 Guidance Manual, the April 2026 CMS Quarterly OASIS Q&As, the OASIS-E2 Change Table, and the Falls with Major Injury Respecification Technical Specification Report. No vendor blogs, no association summaries. If a statement is in this article, it came from a CMS document and is linked.

Why a Post-Deadline Checklist Matters

The pre-deadline guides — including our own OASIS-E2 changes overview — were written off the draft manual and the change table. CMS finalized the manual in late February 2026. Since then, real assessments have been completed, real questions have surfaced, and the April Quarterly Q&A is CMS's first official response to those questions.

CMS made the precedence rule explicit in Question 2 of the April Q&A:

"At times CMS provides new or refined instruction that supersedes previously published guidance. In such cases use the most recent guidance."

Translation: the April 2026 Q&A overrides anything earlier — including the OASIS-E2 Guidance Manual itself — where they conflict. Agencies that QA'd their workflow off the manual in March need to re-check it against the Q&A this week.

Checklist 1 — AI and Ambient Documentation

The single most-asked question post-deadline: can clinicians use ambient AI scribes to populate OASIS items? CMS answered it in Q1 of the April 2026 Q&A.

The scenario CMS addressed: a clinician's iPad uses an ambient listening AI platform (with patient consent) to populate OASIS responses during a Start of Care assessment. The clinician then reviews each item and corrects anything the AI got wrong.

CMS's answer: That scenario is compliant with Convention #9, as long as the clinician — not the software — is responsible for the final code on every item. CMS stated:

"An agency's software may not 'answer' or 'generate' a final code for the OASIS items. Following agency policies, the assessing clinician is responsible for considering available information and ensuring the appropriate OASIS item response(s) were selected, within the appropriate timeframe and consistent with data collection guidance."

What to do this week:

• If your EHR or AI tool auto-populates OASIS items, confirm the clinician sign-off step requires per-item review (not a single bulk "approve all" button)
• Update your OASIS policy to explicitly assign final-code responsibility to the assessing clinician, even when AI assists
• Document patient consent for ambient AI capture as a separate workflow step
• Verify your audit trail captures both the AI-suggested code and the clinician-confirmed code for every item

CMS also clarified in Q3 that collaboration is allowed for OASIS data collection if agency policy permits — only the assessing clinician is responsible for completing and signing the comprehensive assessment, but collecting the underlying data can be a team effort. If your agency wants to limit OASIS to data the assessing clinician personally collected, that's also CMS-compliant.

Checklist 2 — Falls Documentation (Highest Audit Risk)

CMS spent four of the 14 Q&As on falls (Q6 through Q8 explicitly, plus changes in the underlying Falls with Major Injury measure). This is the area CMS is most actively scrutinizing.

What changed in the data set itself

In OASIS-E1, J1900B (Injury except major) and J1900C (Major injury) had inline definitions. In OASIS-E2, those definitions were removed from the item text — the data set now simply says "As described in the OASIS manual." Per Q6, EHR vendors may add the definitions back into the assessment screen as long as the OASIS item language and response options aren't modified.

Major injury — the official definition

CMS reaffirmed in Q6 and Q7 that major injury "includes but is not limited to traumatic bone fractures, joint dislocations/subluxations, internal organ injuries, amputations, spinal cord injuries, head injuries, and crush injuries."

The "includes but is not limited to" phrasing matters. CMS explicitly told agencies in Q7:

"While not required, an agency may utilize Appendix B. Major Injury Diagnostic Codes of the Home Health - Falls with Major Injury Respecification Technical Specification Report in defining a major injury for J1900C - Major injury."

That report is published by CMS at the link in the Sources section below. Agencies can pull that ICD-10 code list as their internal definition of J1900C without having to author their own.

Pathological fractures — CMS Q8 closes the loophole

If a patient falls and the resulting injury is a pathological fracture (e.g., from osteoporosis or metastatic disease) rather than a traumatic one, CMS confirmed in Q8:

• J1800 (Any Falls Since SOC/ROC) is still coded 1 - Yes (the fall happened)
• J1900 (Number of Falls) excludes the pathological fracture from the major injury count
• If there are no other falls or injuries that quality episode, the coding is: J1900A = 1, J1900B = 0, J1900C = 0

What to do this week:

• Pull the Falls with Major Injury Respecification Tech Spec Report and decide whether your agency will adopt Appendix B as the J1900C definition
• Add a pathological-vs-traumatic distinction to your falls documentation template — this is the single most common miscoding CMS is preparing to catch via the respecified measure
• Re-train field staff that all falls outside the home count and falls caused by external forces count, per the expanded J1800 guidance in the OASIS-E2 Guidance Manual
• Audit your last 30 days of OASIS-E2 assessments specifically for falls underreporting

For the underlying definitions and six common scenarios, see Intercepted Falls on OASIS-E2: What Counts and How to Document.

Checklist 3 — GG Functional Scoring (PDGM Risk)

CMS used Q4 and Q5 to clarify the two GG questions agencies have been asking since April 1.

GG0170C — "with no back support" refers to the end position

For GG0170C (Lying to sitting on side of bed), the phrase "with no back support" describes the patient's final position, not the entire transition. If the patient needs trunk support during the transition itself, you code based on the type and amount of assistance required — you do not automatically code "activity not attempted."

GG0170 walking items — when to use "activity not attempted"

CMS Q5 closes a long-standing gray area. If a patient can technically walk 10/50/150 feet but is unsafe doing it even with assistance, the activity is not coded as "01 - Dependent." It's coded with the appropriate "activity not attempted" code.

The CMS rule:

"When coding activities in Section GG, clinicians should code based on the type and amount of assistance required to complete the activity, allowing the patient to perform the activity as independently as possible, as long as they are safe."

What to do this week:

• Re-train PT/OT/RN staff on the safety qualifier for GG0170 walking items — this is a documented PDGM-relevant change
• Update your GG documentation template to prompt the clinician to confirm safety before assigning a numeric code
• Audit the last 30 days of GG0170 walking codes for patients with documented gait instability — if "01 - Dependent" was used, it likely needed an "activity not attempted" code instead

The CY 2026 PDGM recalibration ties payment more tightly to functional scoring than ever before. Inconsistent GG coding now costs more per error.

Checklist 4 — ROC Workflow (Three New Items)

The ROC sequence change is the highest-volume operational shift in OASIS-E2. Three items that were SOC-only in OASIS-E1 are now collected at SOC and ROC:

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

These items appear before B1300 (Health Literacy) in the new ROC flow. The M1000 skip pattern was updated accordingly: "If NA → Skip to B0200" (was: skip to B1300).

What to do this week:

• Confirm your EHR's ROC assessment includes B0200, B1000, and A1110 in the correct sequence
• Re-train ROC-performing clinicians (typically RN case managers) on the three new items
• Verify your post-hospitalization assessment template prompts for sensory and language reassessment — these often change after an inpatient stay
• Spot-check completed ROC assessments since April 1 for blanks on these three items

Checklist 5 — A1255 Transportation Setup

A1255 replaced A1250. The two items look similar but have different timeframes, response codes, and time points. Three things that frequently get misconfigured:

• 12-month lookback, not 6 months
• Response codes are 0 = Yes, 1 = No, 7 = Declines, 8 = Unable (different from the old A1250 alpha codes)
• Not collected at Discharge — SOC and ROC only

What to do this week:

• Open a SOC or ROC assessment in your EHR and confirm the A1255 question text matches the CMS-final wording (12 months, "reliable" transportation, "meetings, work" included)
• Open a Discharge assessment and confirm A1255 does not appear — if it does, file a vendor ticket today
• Re-train intake/admissions staff on the new response codes — old A1250 muscle memory is the #1 source of A1255 errors

For two real scoring scenarios, see A1255 Transportation: How to Score It Correctly.

Checklist 6 — A0810 Sex (No Self-Identification)

A0810 replaced M0069. The response options are unchanged (1 = Male, 2 = Female), but the guidance phrase "If the patient does not self-identify" has been removed. CMS aligned this item with Social Security Administration administrative data standards — it's no longer a self-reported clinical item.

What to do this week:

• Confirm your intake script uses the patient's Medicare administrative record for A0810, not patient self-report
• Update SOC documentation training materials that reference the old M0069 language

For the deeper reasoning, see A0810 Replaces M0069: The New OASIS-E2 Sex Item, Explained.

Checklist 7 — D0150 Dash Use (Sparingly)

OASIS-E2 newly allows a dash response in Column 2 (Symptom Frequency) of D0150. CMS has been clear that this should be rare — used only when a patient confirms a symptom but cannot report frequency.

The April Q&A didn't address D0150 directly, but the precedence rule from Q2 applies: if a future Q&A clarifies dash use further, that supersedes the manual. For now, the manual's "rare" qualifier stands.

What to do this week:

• Confirm your EHR's D0150 input allows a dash entry in Column 2 (it must, per the data spec)
• Add a QA flag for any clinician using more than ~10% dashes in Column 2 — this signals either a workflow problem or a training gap

Checklist 8 — Items CMS Confirmed Are Real Concerns

Three more April Q&A items worth attention even though they aren't OASIS-E2 changes per se:

• K0520D Therapeutic Diet (Q9): Physician-prescribed "double portions" qualify as a therapeutic diet. The defining factor is why it's prescribed, not what is served.
• M1311 Pressure Ulcers (Q12): Remote skin assessment via video or photo review cannot replace the in-person first skin assessment. Collaborative input from a wound specialist is fine; remote-only is not.
• M1610 Urinary Catheter (Q13): Code 2 - Patient requires a urinary catheter only applies if catheter use has been initiated. A catheter that's been ordered but not yet in the home, or refused by the patient, does not qualify.

These weren't introduced by OASIS-E2 but are common audit findings — and CMS used the April Q&A to clarify them, which means they're enforcement priorities.

CMS Source Documents (the only ones you need)

Every statement in this checklist is sourced from one of the documents below. If you build internal training materials, point your team to these — not third-party summaries.

• Final OASIS-E2 Guidance Manual (effective April 1, 2026)
• April 2026 CMS Quarterly OASIS Q&As — published April 21, 2026
• OASIS-E2 Change Table
• OASIS-E2 Data Submission Specifications V3.02.0 — effective April 1, 2026
• Falls with Major Injury Respecification Technical Specification Report (Home Health) — includes Appendix B ICD-10 list
• OASIS Quarterly Q&A archive (QTSO) — bookmark this; July 2026 Q&A is the next release
• OASIS Data Sets page
• OASIS User Manuals page
• CY 2026 HH PPS Final Rule (CMS-1828-F) Fact Sheet
• Home Health QRP Spotlight & Announcements — CMS posts new HH QRP guidance here

CMS Home Health Quality Helpdesk: HomeHealthQualityQuestions@cms.hhs.gov

Frequently Asked Questions

When is the next CMS Quarterly OASIS Q&A?

CMS publishes Quarterly OASIS Q&As approximately every three months. The April 2026 release was posted April 21, 2026. The next release is expected July 2026. Bookmark the QTSO Quarterly Q&A archive.

Does the April 2026 Q&A override the OASIS-E2 Guidance Manual?

Yes, where they conflict. CMS explicitly stated in Q2 of the April Q&A: "At times CMS provides new or refined instruction that supersedes previously published guidance. In such cases use the most recent guidance."

Can my agency use AI to populate OASIS items?

Yes, with conditions. Per April 2026 Q&A Q1, ambient AI tools may populate OASIS responses during the assessment, but the assessing clinician must review and confirm the final code on every item. Software cannot generate the final code on its own.

Can my EHR vendor add the J1900B and J1900C injury definitions back into the assessment screen?

Yes. Per April 2026 Q&A Q6, vendors may add the OASIS-E2 Guidance Manual definitions to the screen as long as the official OASIS item language and response options are not modified. The data set itself simply references "the OASIS manual."

How do I code a fall that results in a pathological fracture?

Per April 2026 Q&A Q8, J1800 is still coded 1 - Yes (the fall happened), but the pathological fracture is excluded from J1900 major injury counts. If there were no other falls or injuries that episode: J1900A = 1, J1900B = 0, J1900C = 0.

Where can I find the official ICD-10 list CMS uses for major injury?

Appendix B of the Home Health Falls with Major Injury Respecification Technical Specification Report. Per April 2026 Q&A Q7, agencies may use this list to define J1900C internally — it's optional but officially blessed.

Is there a grace period for OASIS-E2?

No. The OASIS-E2 Guidance Manual confirms M0090 (Date Assessment Completed) determines the version. Any assessment with M0090 of April 1, 2026 or later uses OASIS-E2.