A resumption of care, or ROC, is the comprehensive assessment a home health agency completes when a patient it did not discharge comes home from an inpatient stay of 24 hours or more that was not for diagnostic tests. It reopens the same admission on the same certification period, and it has one of the shortest deadlines in home health: two calendar days.
Most ROC mistakes I've seen come from treating it like a small start of care. It isn't. The trigger is narrower, the window is shorter, and the certification period does not move. This guide walks the whole event in order: the transfer decision that decides whether a ROC is even possible, what counts as a qualifying stay, the three deadline clocks, who goes, and the four ways a ROC collides with the 60-day period. Where CMS sets a rule, it is cited. Where something is just good practice, it says so.
If you only need the deadline table for every OASIS time point, that lives in the OASIS assessment schedule guide. This article is about the ROC itself.
It Starts at the Transfer, Not the Return
Whether a patient can resume care is decided on the day they leave for the facility, when you code the transfer OASIS. The OASIS-E2 Guidance Manual puts it plainly:
"When a patient is transferred to the inpatient facility, it should be assessed if the agency anticipates the patient will be returning to service or not. If the HHA plans on the patient returning after their inpatient stay or if the patient's return to service is unsure, the reason for assessment (RFA) 6 should be completed."
| You code at transfer | What it means | What happens when the patient comes home |
|---|---|---|
| RFA 6, transferred and not discharged | The chart stays open | A resumption of care (RFA 3) |
| RFA 7, transferred and discharged | The admission is closed | A new start of care (RFA 1) with a new certification period |
Two details in the manual that agencies miss:
- You do not need to fix an RFA 6 that never resumed. If the patient does not come back during the current certification period, "no further OASIS is required. The quality episode ended with the Transfer (RFA 6) that was completed. You do not need to cancel the RFA 6 and resubmit the RFA 7, just complete your agency's internal discharge paperwork."
- Post-acute facilities are treated differently from hospitals. For a stay in a skilled nursing facility, inpatient rehab facility, long-term care hospital, or inpatient psychiatric facility, the manual says "CMS expects and recommends (but does not require) the HHA to discharge the patient by completing the RFA 7 and then to readmit the patient with a new Start of Care upon return to home care." If you keep the chart open with an RFA 6 anyway, you owe a ROC on return, as long as it is completed before the period ends.
Tip
Practice, not rule: decide the RFA 6 versus RFA 7 question with the case manager on the day of transfer, and write the reason in the chart. A chart that says "RFA 6, family expects a 3-day stay for IV antibiotics" is easy to defend. A chart that says nothing invites the surveyor to ask why.
What Counts as a Qualifying Stay
The Conditions of Participation set the trigger. The comprehensive assessment must be updated:
"Within 48 hours of the patient's return to the home from a hospital admission of 24 hours or more for any reason other than diagnostic tests, or on physician or allowed practitioner-ordered resumption date." (42 CFR 484.55(d)(2))
So a ROC is required when all three are true:
- The stay was 24 hours or more.
- It was not only for diagnostic tests.
- The agency kept the patient on service through the stay.
A stay under 24 hours does not trigger a ROC. Neither does an admission purely for a workup. Observation status is not an inpatient admission at all: the OASIS-E2 Guidance Manual says "short stay observation periods in a hospital OR time spent in the ER, regardless of duration, do not meet the definition for transfer to an inpatient facility," so there was no transfer and there is nothing to resume. Your agency may still choose to reassess a patient who comes home after a long night in the emergency department, and often should, but that is an agency policy decision, not a CMS requirement. If your agency's policy treats what happened as a significant change in condition, the reassessment is an Other Follow-Up (RFA 5), not a ROC.
The Three Clocks
There is one deadline, but it can start from three different events. The OASIS-E2 Guidance Manual, M0032 coding tips:
"The ROC comprehensive assessment, including OASIS, and ROC assessment document must be completed within 2 calendar days of the facility discharge date, the agency's knowledge of the patient's return home, or a physician-ordered ROC date."
| The clock starts at | When it applies | Example |
|---|---|---|
| The facility discharge date | The usual case | Home Monday, ROC completed by end of Wednesday |
| The agency's knowledge of the return home | The facility or family never told you | You learn Thursday the patient came home Monday; ROC completed by end of Saturday |
| The physician-ordered ROC date | The physician gave a specific resume date | Home September 1, ordered to resume September 4; assessment completed September 4, 5 or 6 |
The regulation says 48 hours. The manual, which is CMS's own operating guidance for the same rule, counts it in calendar days, and the completion date on the OASIS (M0090) is a date with no time on it. Treat the day the patient comes home as day 0. The assessment is on time if it is completed on day 0, day 1 or day 2.
Three things to get right about the ordered-date clock:
- It has to be a date, not a range. "In order to be considered a physician-ordered SOC/ROC date, the physician/allowed practitioner must give a specific date to initiate or resume care, not a range of dates." An order to "resume next week" is not an ordered date, and the 48-hour clock from the return home applies.
- A later order has to arrive before the earlier one lapses. "A revised physician's ordered SOC/ROC date must be received on or before the date of the previous physician's ordered SOC/ROC." If the extension arrives after the first date has passed, the ordered date is void. You report NA for M0102 and the referral date governs.
- The agency is expected to go on that date. The manual says that when the physician specifies a resume date, "the agency is expected to conduct the ROC visit on that date," and then has up to 2 calendar days from it to complete the assessment document.
This is also why a single ROC countdown that only knows the hospital discharge date will be wrong for every patient who has an ordered resume date, and every patient whose return you learned about late. It has to know all three.
Who Goes, and Whether Care Can Start First
Care can begin before the ROC assessment is done. The manual is explicit:
"If a patient returns home from the hospital and requires immediate care, such as an injection, services may be provided before the ROC comprehensive assessment is completed. ... The ROC date (M0032) is defined as the date of the first visit following an inpatient discharge, regardless of which qualified clinician ultimately completes the ROC assessment. The ROC assessment must be completed by an RN, PT, OT, or SLP. In this example, an on-call nurse may conduct the first visit and provide the necessary care prior to the completion of the ROC assessment."
That gives you three separate facts:
| Question | Answer | Source |
|---|---|---|
| What is the ROC date? | The date of the first visit after the inpatient discharge, whoever makes it | M0032 coding tips |
| Who may complete the ROC assessment? | A registered nurse, physical therapist, occupational therapist or speech-language pathologist | M0032 coding tips; Guidance Manual section 1.5.6 |
| Who may not? | An LPN or LVN, a physical therapist assistant, an occupational therapy assistant, a social worker, or a home health aide | Guidance Manual section 1.5.6 |
The ROC is an in-person home visit. The manual's rule is that "all OASIS assessments, except transfer to inpatient facility and death at home, require the clinician to have an in-person encounter with the patient during a home visit." A phone call is enough for the transfer OASIS. It is not enough for the resumption.
For a Medicare patient receiving only occupational therapy, the same pairing rule that applies at the start of care applies here: the OT may complete the assessment only when occupational therapy is ordered together with physical therapy or speech-language pathology. That is a Medicare eligibility rule in 42 CFR 484.55(b)(3), and it does not apply to other payers.
What the Visit Has to Cover
A ROC is a full comprehensive assessment, not a check-in. Under 42 CFR 484.55(c) it must include, at a minimum, the patient's current health, psychosocial, functional and cognitive status; their strengths, goals and care preferences; their continuing need for home care; their medical, nursing, rehabilitative, social and discharge planning needs; a review of all medications, including interactions and duplicate therapy; the primary caregiver's willingness, ability and schedule; the patient's representative, if any; and the current OASIS items.
The medication review deserves its own line. The hospital has almost always changed something. The ROC visit is the moment the home medication list, the discharge summary and the pill bottles on the kitchen counter get reconciled by someone qualified to notice a problem.
Expect the plan of care to need updating. The physician or allowed practitioner must review it at least every 60 days or more frequently when there is a significant change in condition (42 CFR 409.43(e)), and a hospitalization often is one. New or changed orders follow the usual rules: a verbal order is enough to act on, as long as it is written down, signed and dated by the clinician who received it, and countersigned before the agency bills.
Warning
Do not confuse the ROC visit with the transfer OASIS you already did. The transfer (RFA 6) was limited data, mostly collectable by phone, due within 2 calendar days of learning about the transfer. The resumption (RFA 3) is the full assessment, in the home, due within 2 calendar days of the return. They are two different assessments with two different clocks, and an agency that does the first well and the second late is the most common pattern I see.
The Certification Period Does Not Move
This is the rule that causes the most trouble, so it gets its own heading. From the manual's recertification guidance:
"Unless the patient has been discharged, the due dates for Follow-Up (recertification) assessments are calculated from the original Start of Care date rather than from the Resumption of Care date."
A patient admitted on March 1 has days 56 to 60 on April 25 through April 29. If that patient is hospitalized March 20 and comes home March 28, the ROC is due by March 30, and the recertification window is still April 25 through April 29. The hospital stay does not add days back. Scheduling software that restarts the 60-day count at every return home will put the recertification weeks late, every time the patient is hospitalized.
When the Return Lands Near the End of the Period
There are four situations, and the manual answers each one.
The patient comes home with weeks to spare. The ROC is due within 2 calendar days. The recertification happens in days 56 to 60 as usual. Two assessments, no overlap.
The patient comes home on day 54 or day 55. The ROC window reaches into days 56 to 60, so one assessment can do both jobs:
"The ROC can serve both resumption and recertification functions if the patient is discharged on day 54 or day 55, and the agency completes a ROC assessment on day 56 or day 57, respectively (providing the physician was in agreement)."
Note the condition. The ROC has to be completed inside the recertification window, and the physician has to be on board. A ROC done on day 55 for a patient who came home on day 54 is on time as a ROC, but it is not in days 56 to 60, so a recertification is still owed.
The patient comes home on day 53 or earlier. The 2-day ROC window closes before day 56, so two assessments are required:
"For example, if the patient is discharged on day 53, and there is no physician-ordered ROC date, the agency would be required to complete a ROC assessment no later than day 55. The agency would then complete a recertification assessment within days 56-60."
The patient is still in the facility when the period ends. The admission is over. "The patient should be discharged at the end of the current 60-day certification period if the patient has not returned to the HHA," and "if a Medicare patient returns to the HHA after an inpatient stay that spans the end of the 60-day certification period, Medicare requires a new start of care assessment." The manual's wording is "a Medicare patient." Nothing stops an agency from handling every payer the same way, and one process is easier to train.
| Return home | ROC due by | Recertification | Assessments |
|---|---|---|---|
| Day 53 or earlier | Return + 2 days | Days 56 to 60 | Two |
| Day 54 | Day 56 | Can be the same visit if completed day 56 or later, with physician agreement | One or two |
| Day 55 | Day 57 | Can be the same visit if completed day 56 or later, with physician agreement | One or two |
| Day 56 to 60 | Return + 2 days, and before the period ends | The ROC may serve as both | One |
| After day 60 | Not applicable | Not applicable | Discharge, then a new start of care |
Count the two days from the right event
Logicly counts the resumption window in calendar days from the return home or the physician-ordered date, flags a late ROC, and knows when a return in days 56 to 60 can be one assessment instead of two.
After the Visit
Two more clocks, both easy to forget because they are not about the visit:
- Transmission. The completed OASIS must be transmitted "within 30 days of completing the assessment of the patient" (42 CFR 484.45(a)). The 30 days run from the completion date on the assessment (M0090), not from the day the patient came home.
- Tracking sheet. "The resumption of care date must be updated on the Patient Tracking Sheet each time a patient returns to service following an inpatient facility stay." Enter the most recent one.
OASIS collection and transmission now apply to every patient the agency serves, not only Medicare and Medicaid; 42 CFR 484.45(a) says "each patient." The ROC rules above are not payer-specific.
Where ROCs Go Wrong
| Mistake | What actually happens | The rule |
|---|---|---|
| Treating the ROC like a start of care with a 5-day window | The assessment is 3 days late and nobody notices | 2 calendar days (Guidance Manual Table 1.2) |
| Waiting for the hospital to call | The "knowledge of return" clock is already running when you find out | M0032 coding tips |
| Sending the LPN who has the patient on their caseload | The first visit is fine, but the ROC assessment still has to be done by an RN, PT, OT or SLP | Section 1.5.6 |
| Restarting the 60 days at the ROC | The recertification lands weeks late | RFA 4 coding tips |
| Doing a ROC after the period ended | The admission was over; a new start of care was required | RFA 6 coding tips |
| Forcing a ROC after an observation stay or an ER visit | There was no transfer, so there is no resumption; a non-required assessment and a visit the plan of care did not call for | 42 CFR 484.55(d)(2); Guidance Manual, RFA 6 and 7 |
Key Takeaways
- The ROC question is answered at the transfer. RFA 6 keeps the chart open; RFA 7 closes it.
- The trigger is a stay of 24 hours or more that was not only for diagnostic tests.
- The deadline is 2 calendar days from the facility discharge, from the agency learning of the return, or from a physician-ordered resume date. Return day is day 0.
- Care can start before the assessment. The ROC date is the first visit back, whoever makes it. The assessment itself is RN, PT, OT or SLP only, in the home.
- The certification period never moves. Recertification counts from the original start of care.
- A return on day 54 or 55 can be one assessment if the ROC is completed in days 56 to 60 with the physician's agreement. A return on day 53 or earlier means two. A stay past day 60 means discharge and a new start of care.
Frequently asked questions
What is a resumption of care in home health?
A resumption of care, or ROC, is the comprehensive assessment a home health agency completes when a patient it did not discharge comes home from an inpatient stay of 24 hours or more that was not for diagnostic tests. It reopens the same admission; it is not a new start of care. On the OASIS it is reason for assessment code 3.
How long does the agency have to complete the ROC OASIS?
Two calendar days. The OASIS-E2 Guidance Manual says the ROC assessment must be completed within 2 calendar days of the facility discharge date, the agency's knowledge of the patient's return home, or a physician-ordered resumption date. The day the patient comes home is day 0, so the assessment is on time if completed by the end of day 2.
Does an overnight observation stay require a ROC?
Not under the Conditions of Participation. 42 CFR 484.55(d)(2) requires the update after a hospital admission of 24 hours or more for any reason other than diagnostic tests. A stay under 24 hours, or an admission only for tests, does not trigger a ROC. Your agency may still choose to reassess, but CMS does not require it.
Does the 60-day certification period restart at the resumption of care?
No. The OASIS-E2 Guidance Manual says recertification due dates are calculated from the original start of care date rather than from the resumption of care date. The patient's days 56 to 60 are where they always were. Only a discharge and a new start of care begin a new period.
What if the patient is still in the hospital when the certification period ends?
The admission ends with the period. The OASIS-E2 Guidance Manual says that if a Medicare patient returns after an inpatient stay that spans the end of the 60-day certification period, Medicare requires a new start of care assessment. The agency completes its internal discharge paperwork and readmits the patient with a new start of care and a new certification period.
Sources
- 42 CFR 484.55: (b)(3) who may complete the comprehensive assessment, (c) its required content, (d)(1) the recertification window, (d)(2) the resumption of care update.
- 42 CFR 484.45(a): transmission within 30 days of completing the assessment.
- 42 CFR 409.43(e): plan of care review at least every 60 days or on a significant change in condition; (d) oral orders.
- CMS, OASIS-E2 Guidance Manual, effective April 1, 2026: section 1.5.5 (in-person requirement and Table 1.2), section 1.5.6 (who completes OASIS), M0032 (resumption of care date), M0100 coding tips for RFA 3, RFA 4, RFA 6 and RFA 7, M0102 (physician-ordered resumption date). Every quotation above is from the April 2026 final manual.
- Related on this site: OASIS assessment schedule guide, tracking 60-day certification periods, and the OASIS schedule calculator.