CMS has released the October quarterly OASIS FAQs. Notably, CMS issued a correction to last quarter's guidance regarding OASIS collection and reporting for Part B outpatient therapy patients treated by a home health agency.
In the July FAQs, CMS had indicated that OASIS requirements applied to these Part B therapy patients. The Alliance challenged this interpretation, noting that these patients are not under a home health plan of care and have never been subject to OASIS collection or reporting.
CMS has now corrected its previous response as follows:
Question 1: Does OASIS data need to be collected and submitted for Medicare Part B Outpatient Therapy service patients that are being seen by a home health agency (HHA)?
Answer 1: CMS is confirming that all outpatient therapy services – PT, OT, SLP – provided by an HHA and billed under the Medicare Part B benefit that do not have a home health plan of care in effect do not require completion of the OASIS.
Please note that this response supersedes the guidance that was published in Question 1 of the July 2025 CMS Quarterly OASIS Q&As
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Mary Carr
Vice President, Regulatory Affairs
National Alliance for Care at Home
Washington DC
+1 (202) 547-7424
mcarr@allianceforcareathome.org------------------------------