OASIS Manual · For admins & DONs
QA Workflow and Corrections
How agencies QA an OASIS assessment before transmission, and the CMS rules for modifying or inactivating a record after iQIES has already accepted it.
CMS source
OASIS-E2 Guidance Manual · Verified 2026-10-16
TL;DR
- Catch errors before transmission. Once iQIES has accepted a record, every fix is a modification or inactivation record of its own.
- A real QA process checks three things: time point and date logic (RFA, M0090, completion window), skip-pattern integrity (children only scored when the parent triggered them), and clinical consistency (does the visit note say the same thing as the M-codes).
- After acceptance you have 24 months from the assessment target date to modify or inactivate a record (the manual's rule; the data specs overview still describes a 36-month iQIES window for an open agency). A modification fixes clinical errors and non-key fields. A wrong key field means inactivating the record and submitting a new one.
Why QA before transmission?
OASIS data are used for multiple purposes, including production of quality reports for agencies, public reports on the Care Compare website, and to determine payment. Thus, it is imperative that the OASIS data that HHAs collect and submit be accurate and complete. [...] This language stipulates that the encoded OASIS data must accurately reflect the patient's status at the time the information is collected. The State survey process for HHAs may include review of OASIS data collected versus data encoded and transmitted to the CMS. [...] It follows that minimizing data errors that could affect accuracy of clinical data or outcome analyses is a necessary condition. This is the responsibility of the agency since, ultimately, agency-level quality reports reflect the data agencies input into the system.
The QA review checklist
For new admissions, review the start of care (SOC) OASIS items and compare them to other admission documentation and two or three subsequent visit notes, if they occur within the first week after SOC. [...] For example, if the SOC OASIS items indicate that the patient is fully independent in ambulation, but other documentation indicates that the patient needs assistance when walking, a data quality problem may exist. Assess for any discrepancies between sociodemographic items (for example, payment source or birth date) in addition to discrepancies in clinical assessments (ICD-10-CM codes, all clinical assessment OASIS items).
Correcting a record before transmission
If clinical documentation must be amended, this is done according to agency policy. Any corrections to OASIS data in the clinical record must also be reflected in the OASIS database maintained by the agency, and if data submission has already occurred, a correction must be transmitted to CMS.
Correcting a record after iQIES accepts it
The following two processes have been established to correct records that have been accepted into iQIES: [...] A Modification record should be used when a record has been accepted into iQIES, but the information in the record contains clinical errors or errors to non-key fields. [...] An Inactivation record should be used when a record has been accepted into iQIES, but the corresponding event did not occur or information in ANY of the key fields is erroneous. Users are not allowed to change data in key fields. If data in the key fields in the current record are inaccurate, the current record must be inactivated, and a new replacement record should be submitted. Effective January 1, 2020, HHAs have 24 months from the assessment target date to submit, modify, or inactivate OASIS records.
Common errors
Related
- M0090, Completion Windows, and Transmission Deadlines — deadlines that QA must meet
- Submitting OASIS to iQIES — the transmission system where corrections are submitted
- OASIS Skip Patterns and Branching Logic — the most common source of items caught in QA