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  • 1.  Oasis for All Impact on Quality Reporting Requirements: QAO Calculation

    Posted 03-24-2025 05:15 PM

    With Oasis for all starting July 1st 2025, has there been any technical consideration made for how these changes may affect QAO performance requirements that are used to inform potential payment penalties in the annual payment update?  (https://www.cms.gov/medicare/quality/home-health/home-health-quality-reporting-data-submission-deadlines).

    • Scenario:
      • A home health agency has significant portion of patients that are private pay (say 25%) who never had a SOC oasis performed as of July 1st 2025.
      • CMS does not require a discharge or transfer oasis for patients that had SOCs prior to July 1st, but due to software limitations, the home health agency is unable to automatically exclude those patients from receiving a EOC oasis starting July 1st  (discharge, transfer etc.) when the software starts to automatically assign oasis assessments to all eligible patients from all payer sources.
        • To be clear, this means that all patients for this agency (minus those with standard exclusion criteria) starting July 1st would have an Oasis automatically on EOC regardless of whether that patient had a SOC oasis was performed.
      • As these patients that never had a SOC oasis are discharged or transferred with oasis timepoints, they are unable to be matched to a SOC oasis episode, thus negatively impacting the QAO quality score that informs the annual payment update.

    Does the home health agency need to implement manual tracking methods/procedures to ensure that it stays above the 90% oasis completion rates to avoid payment penalties, or is CMS taking steps to adjust how  the QAO is impacting annual payment updates for the second half of 2025 data?



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    Matthew Cranny
    Avera McKennan Home Care & Hospice
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  • 2.  RE: Oasis for All Impact on Quality Reporting Requirements: QAO Calculation

    Posted 03-25-2025 12:30 PM

    We need to seek clarification from CMS regarding whether their system has the capability to exclude Non-Medicare/Medicaid patients admitted before July 1, 2025, but have a subsequent OASIS assessment completed and submitted on or after July 1, 2025.



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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
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  • 3.  RE: Oasis for All Impact on Quality Reporting Requirements: QAO Calculation

    Posted 03-27-2025 10:06 AM

    Hi Mary,

    Thank you for responding.  I did reach out to the CMS help desk already (their response is below).  If I am reading their answer correctly, they seem to be saying that:

    •  We don't intend for any voluntary submissions to influence/be calculated into payment/quality measures (among other things)
    • At this time there does not exist a mechanism to reject voluntarily submitted oasis data from those measures, however.

    Looking forward to any clarification you are able to provide after your dialogue with them as with our current software solution it may be difficult to opt out of those voluntary submissions without it being a headache operationally.  Thanks again!

    "Hello Matthew,

    Thank you for your inquiry.

    CMS will monitor the all-payer OASIS data submissions to strengthen our ability to assess the quality of care furnished by HHAs.

    CMS will notify providers when decisions are made for future uses for quality or payment purposes.

    It is not intended that voluntary OASIS data will be used for any of the following initiatives:

    •                    APU, including the QAO metric

    •                    Quality measure calculation, including those measures utilized in the HHVBP model

    •                    HHVBP reports

    •                    iQIES quality reports*

    •                    Risk adjustment

    •                    Publicly reported data

    *Non-quality measures reports (including the HHA Activity Report, HHA Roster Report, HHA Discharge Report, OASIS Agency Final Validation Report, OASIS Submitter Final Validation Report, HHA Error Summary by Agency, and OASIS Error Detail Report) will include any relevant, voluntary OASIS data

    Please note, that while there is no technical submission specification that will cause a subsequent OASIS to be rejected when a Start of Care (SOC) was not submitted first, the SOC should be the first mandatory assessment that is submitted for a non-Medicare/non-Medicaid patient, on or after July 1, 2025.

    Thank you for your commitment to home health quality and value.

     

    ~The CMS Home Health Quality Help Desk Team and CMS Home Health Value-Based Purchasing Help Desk Team

    Information contained in this response may be superseded by guidance or specifications published by CMS at a later date."



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    Matthew Cranny
    Avera McKennan Home Care & Hospice
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    Original Message


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