Agencies should be taking advantage of the voluntary period of submission of Start of Care (SOC) OASIS for all-payors in order to prepare for the changes coming July 1.
 
“This will help with streamlining processes and anticipating any labor needs for successful implementation,” notes Jennifer Osburn, clinical consultant with Healthcare Provider Solutions Inc. based in Nashville, Tenn.
 
Beginning on July 1, agencies will be required to collect and submit OASIS data on all patients, regardless of payor. 
 
The voluntary phase-in period from Jan. 1 through June 30 currently allows agencies the time to test and make adjustments as needed to ensure compliance by July 1.
 
All-payor collection and submission will require more hours of labor for collection, QA review/coding and exportation/validation of OASIS data, Osburn says.
 
However, the return for this additional work often is overlooked. 
 
“If assessing clinicians are performing thorough comprehensive assessments on every patient — including OASIS — formulation of the plan of care and outcomes goals should be more comprehensive as well,” Osburn explains.
 
Additionally, as CMS collects information on all payors, perceived differences in outcomes for traditional Medicare patients and those payors who limit the number of visits would likely also be identified, she adds.

Timeline for OASIS all payor

“The questions I’ve received so far are related to the phase-in period and what OASIS timepoints have to be submitted,” notes Lisa McClammy, senior clinical education consultant with MAC Legacy based in Denton, Texas.
 
The need to submit OASIS on non-Medicare/non-Medicaid patients is based on the line SOC M0090 (Date Assessment Completed), she adds.
 
“If the patient has a SOC M0090 date between 1/1/25 and 6/30/25, the agency has the option to submit those non-Medicare/non-Medicaid OASIS,” she explains. “Beginning July 1, agencies must submit OASIS on all patients with a SOC M0090 date of 7/1/25 and after.”
 
Prioritize OASIS training
 
Educating staff about the new requirements, timeline of implementation and updates to agency processes should occur before rolling out OASIS for all payors, Osburn notes.
 
“Expectations should be set,” she adds. “Then, as changes occur during implementation, agency staff should receive formal updates so that they feel part of the process and know the end goals.”
 
All staff will need to have a good, solid knowledge of the OASIS, adds Apryl Swafford, QA Manager with SimiTree Healthcare Consulting based in Hamden, Conn. 
 
Consider whether all of your OASIS-qualified staff (i.e. RN, PT, OT, ST) know, understand and have the ability to apply OASIS knowledge during an assessment. 
 
“Don’t assume they know if they haven’t been doing it,” Swafford notes.

Assess staffing needs

This will also give agencies an opportunity to see if their current staffing model will meet the increased need for additional OASIS completion.
 
Those with more Medicare and Medicaid patients may be able to adjust and cover the increased load. 
 
However, those with a heavy private pay, private insurance and indigent payor mix will find that they probably have to look at hiring additional staff or changing their payer mix, Swafford says.
 
Anticipate and plan for redundancy in the submission process, Osbourn suggests. This means if the person who exports the OASIS is out sick or on vacation, there are additional staff to perform needed exports and submission reports.
 
“I also recommend a system of saving validation reports in a HIPAA-compliant manner for future reference as they are normally not stored in iQIES indefinitely,” she adds.  
 
OASIS completion is not quick so it’s not realistic to think that an easy fix is just having your current staff complete all of them, Swafford explains.
 
Make sure you are using your staff to the full extent of their certifications and capabilities, she says. “This may free up some qualified OASIS staff if they are currently just making routine visits and no OASIS visits.”

Combat staff resistance to OASIS for all

Be prepared to address any pushback from staff when it comes to collecting OASIS data on all patients. They may not be happy with the additional time and resources needed to meet this new requirement.
 
“Make sure they understand that this is dictated by regulation and not something the agency just decided would be a good idea,” Swafford adds. “While it may be a good idea, they may not be able to see the long-term picture right now.”
 
Explain the “why” behind the change, Swafford says.
 
“Make sure they know this is another step in ensuring that all patients are receiving quality care, regardless of their payor source,” she adds.