Question 1

Are any quality assurance tools available to help us verify that our staff is using the OASIS correctly?

Accepted Answer

We are not aware of any standardized quality assurance tool that exists to verify that clinical staff members are using OASIS correctly. A variety of audit approaches might be used by an agency to validate the appropriate responses to OASIS items. For example, case conferences can routinely incorporate OASIS items as part of the discussion. Multi-discipline cases with visits by two disciplines on adjacent days can contribute to discussion of specific items. (Note that only one assessment is reported as the 'OASIS assessment.') Supervisory (or peer) evaluation visits can include OASIS data collection by two clinicians, followed by comparison of responses and discussion of any differences. Other approaches to data quality monitoring are included in Chapter 2 of the OASIS Guidance Manual.

Question 2

We have educated clinicians that it is a requirement that medication reconciliation be done. With this in mind, is it acceptable to electronically restrict clinicians from using a dash (–) as a response to M2001 - Drug Regimen Review by eliminating it as a response option in the Electronic Medical Record (EMR), understanding that there still may be scenarios where the dash is the only correct response to this item?

Accepted Answer

A dash (–) is a valid response for M2001 - Drug Regimen Review. CMS expects dash use to be a rare occurrence. If elements of the drug regimen review were skipped, (for example drug-to-drug interactions were not completed), a dash should be reported, indicating the drug regimen review was not completed. A dash is also a valid response for this item and indicates no information is available.

Question 3

When completing a comprehensive assessment, is it acceptable for providers to utilize separate paper-based standardized assessment tools or must all assessment tools be embedded into the agency’s paper or electronic comprehensive assessment?

Accepted Answer

There is no Medicare requirement that standardized assessment tools be embedded in the agency's comprehensive assessment, with the exception of tools that are embedded within the OASIS instrument (PHQ-2 to 9, BIMS, etc.). It is acceptable for a clinician to supplement the agency's comprehensive assessment with additional standardized assessment forms to meet the criteria for the OASIS best practice items.

Question 4

While configuring the new OASIS-E items in our EMR system, would it be compliant if additional prompts were added to clarify the reason for coding a 0 response for one or more BIMS Interview Items (C0200 - C0400)? The 0 can have different meanings and the reason for coding the 0 may influence the scoring of C0500 - BIMS Summary Score.

Accepted Answer

HHAs are required to incorporate the OASIS data items exactly as written into the agency's comprehensive assessment. In addition to any required OASIS items, an agency may determine what other assessment items will be included in the agency’s comprehensive assessment(s) to meet regulatory, coverage and clinical needs. In the development and maintenance of the OASIS assessment user tools, vendors are advised to reference the Data Specifications (https://www.cms.gov/Medicare/Quality-Initiatives-PatientAssessment-Instruments/HomeHealthQualityInits/DataSpecifications). While the Data Specifications dictate the assessment instrument items, their applicable time point(s) in the assessment instrument, the exact language of the Items, and each Item’s allowable response options, the Data Specifications do not dictate the format of the graphical user interface (GUI) software presentation of the Items in the assessment instrument. While the item language and response options may not be modified, reformatting of the presentation of the item is left to the user’s discretion, as long as such modification does not impact the accuracy of the item scoring and is presented in a way that makes it clear which items (assessment questions and response options) are part of the OASIS, and which are not.

Question 5

PTS. Can other (agency-specific) items be added to the Patient Tracking Sheet?

Accepted Answer

If the agency typically collects other (non-OASIS) items at SOC and updates them only as necessary during the episode of care, the agency can incorporate those other items into the Patient Tracking Sheet (PTS) as needed for efficient care provision. Examples of such items that would “fit” nicely with the OASIS PTS items would be the patient’s street address, telephone number, or directions to the patient’s residence.

Question 6

PTS. Must the clinician write down/mark every single piece of information recorded on the Patient Tracking Sheet (e.g., could clerical staff enter the address, ZIP code, etc.)?

Accepted Answer

Consistent with professional and legal documentation principles, the clinician who signs the assessment documentation is verifying the accuracy of the information recorded. At the time of referral, it is possible for clerical staff to record preliminary responses to several OASIS items such as the address or ZIP code. The assessing clinician then is responsible to verify the accuracy of these data.

Question 7

What do the “M0000” numbers stand for?

Accepted Answer

The “M” signifies a Medicare assessment item. The following four characters are numbers that identify the specific OASIS item.

Question 8

Per the CY 2019 and CY 2020 Home Health Final Rules, it appears that CMS expects HHAs to discharge a patient if the patient requires post-acute care from a SNF, IRF, LTCH or care in an inpatient psychiatric facility (IPF). The HHA could then readmit the patient, if necessary, after discharge from such setting. This goes against the common current practice of completing a transfer and then Resumption of Care (ROC) for patients transferred to any inpatient setting, unless they are not expected to need further home care. Should we still complete an RFA 6 - Transferred to an inpatient facility – patient not discharged from agency when a patient is transferred into any inpatient setting and we expect to receive the patient back after their inpatient stay, and complete an RFA 7 Transferred to an inpatient facility- patient discharged from agency when we do not expect to receive the patient back after the inpatient stay? Should we still complete an RFA 3 - ROC when a patient is discharged from any inpatient facility while still under the services of the agency?

Accepted Answer

There is no change in the OASIS guidance in how agencies may use RFA 6 and RFA 7 when a home health patient is admitted for an inpatient stay. In the event that a patient had a qualifying hospital admission and was expected to return to your agency, you would complete RFA 6 - Transferred to an inpatient facility – patient not discharged from agency. If the patient was not expected to return to your agency after this inpatient hospital stay, you would compete RFA 7 - Transferred to an inpatient facility - patient discharged from agency. However, if the patient requires post-acute care in a SNF, IRF, LTCH or IPF during the 30day period of home health care, CMS expects and recommends (but does not require) the home health agency 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 the home health agency decides to complete an RFA 6 (Transferred to an inpatient facility - patient not discharged from agency), the home health agency will need to complete an RFA 3 (ROC) upon return to home care as long the ROC assessment is completed prior to the end of the current certification period.

Question 9

M1300’s. Do CMS OASIS instructions supersede a clinical wound nurse training program?

Accepted Answer

CMS references, not clinical training programs should be used to guide OASIS scoring decisions. While CMS utilizes the expert resources of organizations like the Wound Ostomy Continence Nurses Society and the National Pressure Injury Advisory Panel to help suggest assessment strategies to support scoring of the integumentary items, in some cases, the OASIS scoring instructions are unique to OASIS and may not always coincide or be supported by general clinical references or standards. While CMS provides specific instructions on how OASIS data should be classified and reported, OASIS scoring guidelines are not intended to direct or limit appropriate clinical care planning by the nurse or therapist. For instance, even though for OASIS data collection purposes a bowel ostomy is excluded as a surgical wound, such data collection exclusion does not suggest that the clinician should not assess, document and include in the care plan findings and interventions related to the ostomy.

Question 10

M1800s, GG0130, & GG0170. Should we expect to see consistency between a patient’s OASIS “M” and “GG” function codes?

Accepted Answer

Not necessarily. There are differences between items that have the same or similar names. Coding differences may be a result of:

•

What is included or excluded in the activity, or

•

What coding instructions apply to the activity

Each OASIS item should be considered individually and coded based on guidance specific to that item.

Question 11

M1800s, GG0130, & GG0170. Can you please provide clarification for the following situation? Many of my patients are identified by the MAHC-10 as “at risk for falls”. An outsource coding company our agency uses has directed us that any patient that is scored as a fall risk on the MAHC-10 must be coded as requiring at least supervision for the function items (M1800s and GG). This instruction doesn’t always seem to be consistent with general assessment observations, and if also used at discharge, limits the ability to show improvement my patients have made. Is there some specific instruction that has been provided that requires this directed coding?

Accepted Answer

Identifying that a patient is at risk for falls is only one criterion to consider when determining the type and amount of assistance needed for a patient to safely complete functional activities. There is no CMS guidance that requires that a patient scored as "at risk" for falls must be coded as needing supervision (or greater assistance) for any or all of the function OASIS items. Although a patient may meet the MAHC-10’s “at risk for falls” threshold, (e.g., due to age, 3+ diagnoses, age-related vision impairment, and polypharmacy), additional assessment findings (like the patient wears glasses to correct vision impairment, and sits while completing dressing activities) may allow the patient to safely complete some activities without supervision or assistance. Even if a patient is determined to be at risk for falls, each OASIS item should be considered individually and coded based on the item specific guidance and OASIS conventions that apply to each item.

Question 12

M1800s, GG0130, & GG0170. Should we expect to see consistency between a patient’s OASIS “M” and “GG” function codes?

Accepted Answer

Not necessarily. There are differences between items that have the same or similar names. Coding differences may be a result of:

•

What is included or excluded in the activity, or

•

What coding instructions apply to the activity

Each OASIS item should be considered individually and coded based on guidance specific to that item.

Question 13

M1800s, GG0130, & GG0170. Can you please provide clarification for the following situation? Many of my patients are identified by the MAHC-10 as “at risk for falls”. An outsource coding company our agency uses has directed us that any patient that is scored as a fall risk on the MAHC-10 must be coded as requiring at least supervision for the function items (M1800s and GG). This instruction doesn’t always seem to be consistent with general assessment observations, and if also used at discharge, limits the ability to show improvement my patients have made. Is there some specific instruction that has been provided that requires this directed coding?

Accepted Answer

Identifying that a patient is at risk for falls is only one criterion to consider when determining the type and amount of assistance needed for a patient to safely complete functional activities. There is no CMS guidance that requires that a patient scored as "at risk" for falls must be coded as needing supervision (or greater assistance) for any or all of the function OASIS items. Although a patient may meet the MAHC-10’s “at risk for falls” threshold, (e.g., due to age, 3+ diagnoses, age-related vision impairment, and polypharmacy), additional assessment findings (like the patient wears glasses to correct vision impairment, and sits while completing dressing activities) may allow the patient to safely complete some activities without supervision or assistance. Even if a patient is determined to be at risk for falls, each OASIS item should be considered individually and coded based on the item specific guidance and OASIS conventions that apply to each item.

Question 14

When is IV access used for, or during, hemodialysis considered for O0110O1 - IV Access? For example, a patient has an AV fistula and IV access is temporarily obtained during hemodialysis at an outside dialysis center. Would the IV access be considered for O0110O1, or would it be excluded since it is only accessed during dialysis, similar to the exclusions with medications and transfusions that were administered during dialysis in item O0110?

Accepted Answer

If there is a current IV access in place at the time of assessment that is used for dialysis or during dialysis for another purpose, for example a central venous catheter, then check O0110O1 - Special Treatments, Procedures and Programs; IV Access. An AV fistula, whether it is being accessed or not, does not meet the definition of IV Access for O0110O1.

Question 15

When will CMS begin using non-Medicare/non-Medicaid OASIS data for the purpose of calculating a home health agency’s HHQRP Annual Payment Update (APU) compliance?

Accepted Answer

Currently, only OASIS data from Medicare and Medicaid payers are included in HH QRP Annual Payment Update (APU) calculation. To calculate APU, CMS intends to include patient data from all non-Medicare/non-Medicaid patients who begin receiving skilled home health care services with an OASIS SOC M0090 date on or after January 1, 2027. If the M0090 date 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. The transition to using all-payer OASIS data for APU calculation does not impact how assessment data of skilled Medicare/Medicaid patients is utilized. For more information on the HH QRP quality reporting requirements, please see the HHQRP Quality Reporting Requirements webpage.

Category 4a - General Questions

Are any quality assurance tools available to help us verify that our staff is using the OASIS correctly?

When completing a comprehensive assessment, is it acceptable for providers to utilize separate paper-based standardized assessment tools or must all assessment tools be embedded into the agency’s paper or electronic comprehensive assessment?

PTS. Can other (agency-specific) items be added to the Patient Tracking Sheet?

PTS. Must the clinician write down/mark every single piece of information recorded on the Patient Tracking Sheet (e.g., could clerical staff enter the address, ZIP code, etc.)?

What do the “M0000” numbers stand for?

M1300’s. Do CMS OASIS instructions supersede a clinical wound nurse training program?

M1800s, GG0130, & GG0170. Should we expect to see consistency between a patient’s OASIS “M” and “GG” function codes?

M1800s, GG0130, & GG0170. Should we expect to see consistency between a patient’s OASIS “M” and “GG” function codes?

Since the February 2026 release: July 2026 CMS Quarterly OASIS Q&As

When will CMS begin using non-Medicare/non-Medicaid OASIS data for the purpose of calculating a home health agency’s HHQRP Annual Payment Update (APU) compliance?

Retired by CMS

Category 4a - General Questions

Are any quality assurance tools available to help us verify that our staff is using the OASIS correctly?

When completing a comprehensive assessment, is it acceptable for providers to utilize separate paper-based standardized assessment tools or must all assessment tools be embedded into the agency’s paper or electronic comprehensive assessment?

PTS. Can other (agency-specific) items be added to the Patient Tracking Sheet?

PTS. Must the clinician write down/mark every single piece of information recorded on the Patient Tracking Sheet (e.g., could clerical staff enter the address, ZIP code, etc.)?

What do the “M0000” numbers stand for?

M1300’s. Do CMS OASIS instructions supersede a clinical wound nurse training program?

M1800s, GG0130, & GG0170. Should we expect to see consistency between a patient’s OASIS “M” and “GG” function codes?

M1800s, GG0130, & GG0170. Should we expect to see consistency between a patient’s OASIS “M” and “GG” function codes?

Since the February 2026 release: July 2026 CMS Quarterly OASIS Q&As

When will CMS begin using non-Medicare/non-Medicaid OASIS data for the purpose of calculating a home health agency’s HHQRP Annual Payment Update (APU) compliance?

Retired by CMS

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