Blog
Feb 4, 2026
OASIS-E1 in Home Health: Every Change, What It Means, and What Comes Next
Arvind Sarin
Most of the noise around OASIS-E1 focused on what was added: one new item, O0350, asking whether the patient's COVID-19 vaccination is up to date. That framing undersells the change. The more consequential updates were the removals and the revised skip logic, because those are the places where agencies running outdated EMR configurations are quietly submitting records with compliance gaps they have not caught yet.
OASIS-E1 became mandatory on January 1, 2025, following OMB approval in December 2024. It replaced OASIS-E, which had been in effect since January 2023. The changes were deliberately limited in scope, but limited does not mean optional, and it does not mean trivial to implement correctly.
This post covers every item that changed, why CMS made each change, what it means for clinical workflows and QA processes, and what agencies should know about OASIS-E2, which is scheduled for April 1, 2026.
OASIS-E1 vs OASIS-E: The Full Change Set
Eight items changed in the transition from OASIS-E to OASIS-E1. Three were removed entirely, one was added, and four were revised. Here is each change with the reason behind it and what it requires from your team.
Item | Change | Why CMS made it | Workflow impact |
M0110 Episode Timing | Removed | No longer used in PDGM, QRP, or HHVBP since 2020 | Remove from the SOC and ROC forms. Update any EMR workflow that referenced it. |
M2200 Therapy Need | Removed | No longer used in QRP, payment, or HHVBP model | Remove from clinical workflows and any QA checklists that flagged it. |
GG0130 Discharge Goal | Removed from SOC/ROC | HHVBP model changes made discharge goals at admission redundant | Clinicians no longer score discharge goals at SOC or ROC. Discharge assessment GG items unchanged. |
O0350 COVID-19 Vaccination | Added | Supports COVID vaccine quality measure; will appear on Care Compare in 2026 | New field at Transfer, Death at Home, and Discharge timepoints. Answer sourced from record, patient, or caregiver. |
M0102 Skip Pattern | Revised | The previous skip pattern directed to M0110, which was removed | Update EMR skip logic. Staff should re-learn the new conditional path. |
M2420 Discharge Disposition | Revised wording | Clarified that Response 1/2 refers specifically to Medicare-certified HHA services | Review how your agency documents discharge to home with services. Language in the record should match the revised item. |
D0150 Patient Mood Interview | Revised skip pattern | Corrected the mismatch between the item language and the existing guidance manual instructions | Updated EMR logic needed. The interview completion rules now match what the guidance manual has said since 2023. |
M0150 Payment Source | Revised | Expanded to support all-payer reporting across all payer types | Critical change. Verify your EMR captures non-Medicare payer codes correctly. |
The Three Removals: Why They Matter More Than They Look
M0110 Episode Timing
CMS stopped using M0110 for any operational purpose when PDGM replaced PPS in January 2020. Episode timing no longer affects payment calculation, quality reporting, or HHVBP scoring. The item stayed on the OASIS-E form for five years longer than it needed to.
The workflow risk at transition: agencies whose EMR forms still include M0110 post-January 2025 are collecting data that has no regulatory purpose and may confuse clinicians who try to reference old guidance. If your QA team has any checklist items tied to M0110 completion, those need to be retired.
M2200 Therapy Need
Like M0110, M2200 became a legacy item the moment PDGM went live. Under the prior prospective payment system, therapy visit thresholds directly affected payment. Under PDGM, they do not. CMS had no remaining use for therapy need data in payment, QRP, or HHVBP calculations.
Agencies that built internal benchmarks around therapy need documentation should audit whether any of those benchmarks still serve a clinical or operational purpose independent of the OASIS requirement.
GG0130 Discharge Goal at SOC and ROC
This removal drew quiet relief from clinicians. Under OASIS-E, clinicians were required to document functional discharge goals at Start of Care and Resumption of Care, a requirement that asked them to predict discharge-level performance during the admission assessment. CMS removed the discharge goal component from GG0130 at SOC and ROC timepoints to align with HHVBP model changes effective in 2025.
The discharge assessment GG items are unchanged. Discharge goals are still collected at discharge. What changed is that clinicians no longer need to project those goals at admission, which was one of the more clinician-unfriendly requirements in the OASIS-E form.
The Addition: O0350 COVID-19 Vaccination Status
O0350 asks a single question: Is the patient's COVID-19 vaccination up to date? The response options are yes, no, or unknown.
A few specifics that matter for implementation:
O0350 appears at Transfer, Death at Home, and Discharge timepoints only. It is not collected at SOC or ROC.
The information can be sourced from the medical record, the patient, a family member, or another caregiver. It does not require clinical verification.
CMS tied O0350 to a COVID vaccine quality measure finalized in the CY2024 HH PPS Final Rule. The measure will appear on Care Compare starting in 2026, after a full year of data collection.
What counts as 'up to date' is determined by CDC guidance, which can change. Agencies should monitor CDC recommendations and ensure their clinical guidance documents are updated accordingly.
The practical burden of this item is low. The data collection is straightforward and can be sourced from existing records in most cases. The compliance risk comes from agencies that missed the rollout and are not collecting it at all.
The Revisions: Four Items With Operational Impact
M0150 Current Payment Source
M0150 is the item with the largest downstream consequences, and it is the one most agencies underestimated. The revision expanded the payment source field to accommodate all-payer reporting, setting up the infrastructure for the all-payer OASIS mandate that became mandatory July 1, 2025.
If your EMR is not correctly capturing non-Medicare payer codes in M0150, your all-payer OASIS submissions are likely incomplete or miscoded. This is not a theoretical risk. Agencies that handled the all-payer mandate without auditing M0150 configuration are submitting data that does not reflect the actual payer mix.
M0102 Skip Pattern
The previous skip pattern for M0102 (Date of Physician-Ordered Start of Care) directed clinicians to M0110, which no longer exists. CMS updated the skip logic to remove that reference. This is an EMR configuration issue, not a clinical one, but agencies running unpatched systems have a broken assessment path that may be producing errors without surfacing them clearly.
M2420 Discharge Disposition
The language in Responses 1 and 2 was revised to replace 'formal assistive services' with 'skilled services from a Medicare-certified HHA.' The old wording was ambiguous. The revision clarifies that the response applies when the patient is discharged to another Medicare-certified home health agency, not to any formal service arrangement.
QA teams should review whether their documentation language at discharge matches the revised item. If your visit notes use the old 'formal assistive services' language, those records may not hold up clearly under audit review.
D0150 Patient Mood Interview Skip Pattern
The item text in D0150 previously instructed clinicians to continue the PHQ interview based on a condition that did not match the current guidance manual. The guidance manual had already corrected this, but the item itself had not. OASIS-E1 aligned the item language with the guidance that has been in effect since 2023.
If your clinicians were following the item text rather than the guidance manual (a reasonable thing to do), they may have been completing the PHQ interview incorrectly. This is worth a targeted QA review of mood interview documentation going back to 2023.
The All-Payer Mandate: The Bigger Context
OASIS-E1 and the all-payer mandate arrived together, and the connection is not coincidental. The M0150 revision was designed specifically to support all-payer data collection. CMS phased in the mandate through a voluntary period from January through June 2025, then made it mandatory on July 1, 2025. The full regulatory basis is in the CY2025 HH PPS Final Rule.
What the mandate means in practice: agencies that previously completed OASIS for Medicare and Medicaid patients only, typically 60 to 70 percent of admissions, now complete it for every patient receiving skilled services, regardless of payer. Patients receiving only home health aide services, non-skilled services, or homemaker services remain exempt. Pediatric patients remain exempt.
For a mid-sized agency where commercial and private-pay patients represent 35 percent of admissions, this is a 35 percent increase in OASIS volume with no corresponding staffing increase. The agencies managing this without adding documentation burden to their clinical staff are the ones that moved to pre-visit automation before the mandate took effect.
See how pre-visit automation handles all-payer OASIS volume |
What Your EMR Vendor Should Have Done by January 2025
OASIS-E1 compliance is not purely a clinical training issue. A significant portion of the implementation burden sits with EMR configuration. Your vendor should have:
Removed M0110 and M2200 from the SOC and ROC assessment forms
Removed discharge goal prompts from GG0130 at SOC and ROC timepoints
Added O0350 to Transfer, Death at Home, and Discharge assessments
Updated the M0102 skip pattern to remove the reference to M0110
Revised M2420 response language
Updated D0150 skip pattern logic to match the guidance manual
Expanded M0150 to capture non-Medicare payer codes for all-payer reporting
If you have not confirmed these changes with your vendor in writing, do it now. Verbal assurance that a system 'is updated' is not sufficient documentation. Request a release note or change log that specifically identifies each OASIS-E1 item.
Audit recommendation: Pull a sample of ten SOC records submitted after January 1, 2025. Check whether M0110 or M2200 appears in any of them. Check whether O0350 appears on discharge records. If either finding is wrong, your system was not updated correctly, and your submissions carry compliance exposure. |
OASIS-E2 Is Coming April 1, 2026
CMS submitted the OASIS-E2 Paperwork Reduction Act package in mid-2025 and published draft instruments in August 2025 (source: CMS.gov, OASIS Data Sets). The April 1, 2026, effective date is an off-cycle rollout, departing from the traditional January 1 cadence.
Key changes in OASIS-E2 that agencies should begin preparing for now:
A1255 Transportation replaces A1250 Transportation, with revised wording to align with other CMS programs
O0350 COVID-19 vaccination status is proposed for removal
B0200 Hearing and B1000 Vision items added to the Resumption of Care timepoint
A1110 Language added to the ROC timepoint
M0069 Gender item removed; A0810 added as replacement
These changes follow the same logic as OASIS-E1: aligning home health data with cross-setting CMS standards and removing items that no longer serve payment or quality reporting functions. Agencies that handled OASIS-E1 implementation late should use the period before April 2026 to build a more structured process. Our OASIS documentation automation guide covers how pre-visit platforms can absorb these instrument changes without retraining clinical staff from scratch each cycle.
Common Questions
Is OASIS-E1 the same as OASIS-E?
No. OASIS-E1 replaced OASIS-E on January 1, 2025. OASIS-E was in effect from January 2023 through December 2024. OASIS-E1 removed three items (M0110, M2200, GG0130 discharge goals at SOC/ROC), added one (O0350), and revised four others. Agencies submitting records after January 1, 2025 must use OASIS-E1 item logic.
Which OASIS items were removed in OASIS-E1?
Three items were removed: M0110 Episode Timing, M2200 Therapy Need, and GG0130 Discharge Goals at Start of Care and Resumption of Care timepoints. M0110 and M2200 had not been used in PDGM payment, quality reporting, or HHVBP since 2020. The GG0130 discharge goal removal aligned with HHVBP model changes effective in 2025.
Does OASIS-E1 apply to non-Medicare patients?
OASIS-E1 governs the instrument itself. The all-payer mandate, which became mandatory July 1, 2025, determines which patients require OASIS completion. Under the mandate, OASIS is required for all patients receiving skilled services from a Medicare-certified agency, regardless of payer. Patients receiving only home health aide, non-skilled, or homemaker services remain exempt. Pediatric patients remain exempt.
When does OASIS-E2 take effect?
OASIS-E2 is scheduled for April 1, 2026, an off-cycle implementation date. Draft instruments were published by CMS in August 2025. Key changes include revised transportation items, removal of O0350, and additions to the ROC timepoint. Agencies should begin vendor conversations about OASIS-E2 configuration updates in late 2025.
What happens if our EMR was not updated for OASIS-E1?
Records generated with pre-OASIS-E1 item logic after January 1, 2025, may contain deprecated items or missing required fields. This creates compliance exposure if records are reviewed under audit. Run a sample audit of SOC and discharge records submitted after January 1, 2025, and confirm with your EMR vendor which specific configuration changes were made and when.
How Automation Absorbs Instrument Changes
Every OASIS instrument update creates the same operational problem: clinical staff needs retraining, EMR configurations need patching, and QA teams need new checklists. Agencies running manual documentation workflows go through this cycle with every version change. Agencies using pre-visit automation platforms absorb most of it at the platform level. When CMS removes an item, the platform stops populating it. When an item is added, the platform collects it from the referral or prior episode context. When skip logic changes, the platform applies the updated rules before the clinician ever sees the record. The transition from OASIS-E to OASIS-E1 is a good example of why instrument-agnostic automation has a different cost structure than manual workflows over a multi-year horizon.
