CMS clarified on July 6 that all-payer OASIS is moving from collection to payment consequences. OASIS is already required for non-exempt patients with any payer when the SOC M0090 date is July 1, 2025 or later. For Annual Payment Update calculations, CMS intends to add non-Medicare/non-Medicaid patients whose SOC M0090 date is January 1, 2027 or later. The quality-assessment-only standard is 90%; falling short can reduce an HHA’s annual payment update by two percentage points.

DomAfina’s take: private-pay and commercial cases can no longer live in a lighter documentation lane. Before January, run an all-payer OASIS census against admissions, confirm every applicable start of care produced the full assessment sequence, and make payer changes visible to QA. Audit CMS’s exemptions—minors, maternity-only, personal-care-only and single-visit cases—so staff do not treat “private pay” as the exemption. The risk is not one missing form. It is an invisible denominator.

Source reviewed: CMS: Home Health Quality Reporting Requirements. The source supports the reported update; the operational recommendations are DomAfina’s analysis.