All-payer OASIS did not start in 2027. Since July 1, 2025, every skilled patient who is not exempt and starts care on or after that date has needed the full OASIS, submitted to iQIES, whoever pays. What changes on January 1, 2027 is that those patients start to count: CMS says it "intends to include patient data from all non-Medicare/non-Medicaid patients" whose start-of-care OASIS (M0090) is dated on or after January 1, 2027 in the calculation that decides your annual payment update. That calculation needs 90 percent quality assessments, and missing it costs 2 percentage points of your Medicare update.
Updated November 12, 2026. Sources: CMS's Home Health Quality Reporting Requirements (opens in a new tab) page (last modified July 7, 2026), its July 6, 2026 notice "All-Payer Related Changes to the Home Health Quality Reporting Program Annual Payment Update" on the HH QRP Spotlight (opens in a new tab), the CY 2023, CY 2025 and CY 2027 home health final rules, and CMS's October 2026 guidance on pay source changes.
The Timeline
Counted by the M0090 date of the patient's start-of-care OASIS:
| Start of care (M0090) | OASIS for non-Medicare, non-Medicaid patients | Counts toward the APU's 90%? | Source |
|---|---|---|---|
| Before January 1, 2025 | Not required; the suspension in the 2003 Medicare Modernization Act still applied | No | CY 2023 and CY 2025 final rules |
| January 1 – June 30, 2025 | Voluntary phase-in | No | CY 2023 and CY 2025 final rules |
| July 1, 2025 – December 31, 2026 | Required, at every time point of the stay | No. "Currently, only OASIS data from Medicare and Medicaid payers are included" | CMS HH QRP Requirements page |
| On or after January 1, 2027 | Required | Yes, as CMS intends. First in the 2029 APU (calendar year 2027 data) | CMS HH QRP Requirements page; CY 2027 final rule, Table 20 |
Medicare and Medicaid patients, including Medicare Advantage and Medicaid managed care, have counted all along. CMS: "The transition to using all-payer OASIS data for APU calculation does not impact how assessment data of skilled Medicare/Medicaid patients is utilized."
One rule catches agencies out. "If the M0090 for the SOC is before January 1, 2027, for a non-Medicare/non-Medicaid patient, no OASIS data from any of their time points throughout their entire home health admission will be used for APU purposes, including any assessments that may be completed on or after January 1, 2027." A private-pay patient admitted on December 28, 2026 never enters the count. One admitted on January 4, 2027 does, through to discharge.
Who Must Have an OASIS
The requirement covers "patients with any pay source who are not exempt from OASIS data collection," from the start of care through "resumption of care, recertification, other follow up, transfer, discharge, and death at home." The CY 2026 final rule also changed the wording of the Conditions of Participation (42 CFR 484.45 and 484.55) to make clear that OASIS reporting "applies to all HHA patients receiving skilled services."
CMS's July 2026 notice lists six exempt groups:
- Patients under the age of 18
- Patients receiving maternity services only
- Patients receiving personal care, homemaker or chore services only
- Patients receiving outpatient therapy from the agency, billed under Medicare Part B, with no home health plan of care in effect
- Patients receiving a service from a company other than the Medicare-certified agency, using the agency's staff under a loaned employee agreement
- Patients receiving only a single visit in a quality episode
Commercial insurance, self-pay and every other payer are in. The payer does not change the schedule: the same time points and the same 60-day recertification window apply. The OASIS Schedule Calculator works them out from a start-of-care date, and the RFA Picker gives the reason for assessment for each.
How the 90 Percent Is Counted
42 CFR 484.245(b)(2)(ii)(A) sets the threshold "at 90 percent of all required OASIS or successor instrument records." CMS measures it with what it calls the Quality Assessments Only (QAO) formula:
QAO = quality assessments ÷ (quality assessments + non-quality assessments) × 100
In short, a start or resumption of care with a matching end-of-care assessment (transfer, discharge or death) counts as quality, and so do both halves of that pair. A start of care in the last 65 days of the period, or an end of care in the first 65 days, counts too, because its partner may fall outside the year. A one-visit episode counts. Recertifications and other follow-ups are neutral. Anything else, most often a start of care whose discharge was never done or never submitted, is a non-quality assessment and pulls the rate down. CMS's methodology document (opens in a new tab) has the full set.
CMS on the threshold from 2027: "HHAs will be required to achieve a quality reporting compliance rate of 90 percent or more for all submitted OASIS data regardless of payer source."
Why It Matters More in 2027
Three changes land together:
- Calendar-year APU periods. The CY 2027 final rule makes the OASIS APU year January 1 through December 31, starting with the 2029 APU (calendar year 2027 data). The six months from July 1 through December 31, 2026 are a bridge that sets the 2028 APU.
- A shorter correction window. The same rule requires agencies to submit "and make corrections" to OASIS data by the 15th day of the second month after each quarter. CMS's Table 19 dates for 2027: May 17, 2027 for the first quarter, August 16, 2027 for the second, November 15, 2027 for the third and February 15, 2028 for the fourth. A private-pay discharge that sits unsubmitted past those dates is a non-quality assessment for good.
- Discharges at a payer change are now required. See the next section.
When the Payer Changes
CMS's October 2026 guidance on pay source changes (opens in a new tab) turns a recommendation into a rule. Its test is one question: "Does the new payer require a new SOC?" If it does, "effective October 20, 2026, a discharge OASIS is required, and a new SOC comprehensive assessment would be completed under the new pay source." CMS adds that the agency "does not have to re-admit the patient in the sense that it would normally admit a new patient."
| Payer change | New start of care? |
|---|---|
| Any payer to Medicare fee-for-service | Yes |
| Medicare fee-for-service to skilled care under Medicare Advantage | No |
| Medicare fee-for-service as secondary to Medicare fee-for-service as primary | No |
| Any other skilled-to-skilled change (to or from Medicaid, Medicare Advantage or another payer) | Depends on whether the new payer requires one |
| Skilled care under any payer to non-skilled care | No start of care; a discharge OASIS is required |
| Non-skilled care to skilled care under any payer | Yes |
The guidance says it "supersedes the guidance found in the OASIS Guidance Manual and in the CMS OASIS Q&As that recommends but does not require the patient to be discharged from the previous pay source."
For the QAO count, that discharge is what closes the first quality episode. Skip it and the earlier start of care has no partner.
What Does Not Change
- Quality measures and Star Ratings. CMS's data submission deadlines page: "OASIS-based measures continue to be calculated for Medicare fee-for-service, Medicare Advantage (Medicare managed care), Medicaid, and Medicaid managed care patients only. CMS will monitor the all-payer OASIS data and will notify providers when decisions are made for future uses for quality or payment purposes."
- Payment. In the CY 2025 final rule, CMS wrote: "The implementation of mandatory all-payer data collection and submission is also not intended to impact payment policy."
- The items. Private-pay patients get the same OASIS-E2 instrument as everyone else.
A Check Before January 1
- Pull your latest QAO performance report from iQIES and look at the non-quality assessments. Most are start-of-care records with no discharge. Those habits will start costing you in 2027.
- List every open non-Medicare, non-Medicaid patient. Anyone whose start of care is before January 1, 2027 stays out of the APU count for the whole stay. Anyone admitted from January 1 is in.
- Make discharge and transfer OASIS a hard step for every payer. Assign who completes and submits them, and check the iQIES Final Validation Report the next day.
- Write the payer-change rule into intake and billing. Since October 20, 2026, a change to a payer that requires a new start of care means a discharge OASIS first.
- Put the 2027 quarterly deadlines on the calendar: May 17, August 16 and November 15, 2027, and February 15, 2028.
- Check records before they go up. The OASIS-E2 Submission Validator catches the fatal edits agencies hit most, and the OASIS Edit Code Lookup reads any edit ID back to CMS's rule.
If your agency got a non-compliance letter for the CY 2027 APU, the request for reconsideration is due by November 23, 2026: see how to file it.
Know when each recert is due
Enter the start of care, and Logicly works out each 60-day cert period and the recertification window. The dashboard shows what is due.
Key Takeaways
- All-payer OASIS has been required since July 1, 2025 for every non-exempt skilled patient, by start-of-care M0090 date.
- From January 1, 2027, CMS intends to count non-Medicare, non-Medicaid admissions in the 90 percent QAO threshold. The first payment year affected is the 2029 APU.
- A non-Medicare, non-Medicaid patient admitted before January 1, 2027 stays out of the count for the whole stay.
- Since October 20, 2026, a payer change that needs a new start of care needs a discharge OASIS first.
- Quality measures and Star Ratings still use Medicare, Medicare Advantage, Medicaid and Medicaid managed care patients only.
Frequently Asked Questions
When did all-payer OASIS start?
Collection and submission became mandatory for patients with an OASIS start of care (M0090) date on or after July 1, 2025, whatever the pay source, unless the patient is exempt. January 1 through June 30, 2025 was a voluntary phase-in. CMS finalized the requirement in the CY 2023 home health final rule and set the start-of-care trigger in the CY 2025 rule.
What changes for all-payer OASIS on January 1, 2027?
The data starts to count toward your annual payment update. CMS says it intends to include non-Medicare and non-Medicaid patients whose start of care M0090 date is on or after January 1, 2027 in the APU calculation. Until then, only Medicare and Medicaid OASIS data count. The first payment year this reaches is the 2029 APU, which the CY 2027 final rule bases on calendar year 2027 data.
What is the 90 percent OASIS threshold?
42 CFR 484.245(b)(2)(ii)(A) requires an agency to meet a threshold set at 90 percent of all required OASIS records. CMS measures it with the Quality Assessments Only formula: quality assessments divided by quality plus non-quality assessments, times 100. Agencies below 90 percent lose 2 percentage points of their annual payment update.
Which patients are exempt from OASIS?
CMS lists six groups: patients under 18, patients receiving maternity services only, patients receiving only personal care, homemaker or chore services, Part B outpatient therapy patients with no home health plan of care, patients served under a loaned employee agreement by another company, and patients receiving only a single visit in a quality episode.
Do private-pay patients now count in Star Ratings?
Not yet. CMS's data submission deadlines page says OASIS-based measures continue to be calculated for Medicare fee-for-service, Medicare Advantage, Medicaid and Medicaid managed care patients only, and that CMS will tell providers when it decides on other uses.
Sources
- CMS, Home Health Quality Reporting Requirements (opens in a new tab): the all-payer schedule, the six exemptions, the January 1, 2027 APU change and the QAO formula. Last modified July 7, 2026; read November 7, 2026.
- CMS, HH QRP Spotlight and Announcements (opens in a new tab): "All-Payer Related Changes to the Home Health Quality Reporting Program Annual Payment Update (APU)," July 6, 2026.
- CMS, Home Health Quality Reporting Data Submission Deadlines (opens in a new tab): OASIS-based measures still calculated for Medicare and Medicaid patients only. Last modified July 1, 2026.
- CMS, Home Health Guidance Related to Pay Source Changes (opens in a new tab), last updated October 20, 2026, from the OASIS User Manuals (opens in a new tab) page.
- CMS, Pay for Reporting: Quality Assessments Only Methodology (opens in a new tab).
- CY 2023 HH PPS final rule, 87 FR 66790 (opens in a new tab) (November 4, 2022), section D: the end of the suspension and the CY 2027 program year start.
- CY 2025 HH PPS final rule, 89 FR 88354 (opens in a new tab) (November 7, 2024), section III.E: the start-of-care trigger and the July 1, 2025 mandatory date.
- CY 2026 HH PPS final rule, 90 FR 55342 (opens in a new tab) (December 2, 2025), section V: the Conditions of Participation wording.
- CY 2027 HH PPS final rule, CMS-1844-F, FR Doc. 2026-22750 (opens in a new tab), on public inspection November 4, 2026, published November 9, 2026 at 91 FR 72022: Table 19 (2027 submission deadlines) and Table 20 (APU data periods).
- 42 CFR 484.245 (opens in a new tab)(b)(2)(ii): the 90 percent threshold.