Preparing for OASIS-E2: Understanding Changes Outlined in the OASIS-E2 Final Guidance Manual

The implementation of OASIS-E2, effective April 1, 2026, brings several important updates that home health agencies should be aware of. In this overview, we’ll walk through key details of the changes, what they mean for clinicians and agencies, and what to expect as the new version of OASIS takes effect.

As we move into this newly revised OASIS document, the Final Guidance Manual was released just this past week. In reviewing it, we noted that the draft version included a statement indicating that clinicians would not be permitted to use automated systems to generate or populate responses directly on the OASIS. This language has drawn considerable scrutiny since the proposed manual was released, particularly given the rapid expansion of AI across the industry, with many EMR systems now incorporating AI capabilities. As a result, this has become a significant point of concern.

In the Final Guidance Manual, that statement was not changed. However, additional clarification indicates that while an AI system cannot technically complete or populate the OASIS responses on behalf of the clinician, it does not prohibit the use of such systems to review the OASIS, assist with quality checks, or provide guidance that may help clinicians determine the appropriate response. The key distinction is that the clinician must ultimately make and enter the response themselves; the system cannot independently complete the OASIS item.

It’s also important to review some of the updates included in the OASIS Final Guidance Manual, as several topics that were previously addressed only in the quarterly Q&As have now been incorporated directly into the manual. At this point, the first quarter 2026 Q&As have not yet been released.

Regarding the April 1 implementation of the OASIS-E2, there are a few updates, though not as many as some might expect. The transportation question (A1250) will receive a number change and includes a slight variation in the available response options. The gender item, M0069, is being renumbered to A0810 and will now be titled “Sex,” with male and female as the only response options.

For Resumption of Care, OASIS-E2 will now include the hearing, vision, and language questions. These items currently appear on the Start of Care OASIS and will remain unchanged; they are simply being added to the Resumption of Care assessment.

We view this change as a potential indicator of what may be coming next. Both the Start of Care and Resumption of Care assessments are used in different ways when calculating quality measures. With the addition of these three items to the Resumption of Care, it suggests they may eventually play a role in a future outcome or quality measure, or possibly be used for risk adjustment. Regardless, these items will officially be included in the Resumption of Care assessment beginning April 1.

They will also be removing the COVID-19 vaccination question (O0350), which was expected. In addition, the COVID-19 quality measure has already been removed from the public reporting site.

Lastly, three items had been proposed for inclusion in a new OASIS update planned for January 2027 including questions related to living situation, food, and utilities. These Social Determinants of Health items will not be included in the new OASIS, and at this time there are no plans for them to be added to an OASIS update in 2027.

As part of the Home Health Final Rule, there was also a Request for Information (RFI) section that sought feedback on several topics to help guide future policy decisions. One of the areas specifically addressed was Social Determinants of Health, including whether and how these factors might be incorporated into future quality measures.

With the implementation of OASIS-E2, Healthcare Provider Solutions offers a five-part training series that your staff can use for education and preparation. The training is available for download and includes a 10-question quiz for each of the five sections. Currently, the version available on our website reflects OASIS-E1. However, we are in the process of recording the updated OASIS-E2 version now that the final guidance manual has been released. We expect the updated training series to be available on our website by the end of March.

On March 19, Jennifer Osburn, a clinical consultant at HPS, will present the HPS Alliance exclusive webinar, “Home Health OASIS E2 – What Lies Ahead!”. To register for this webinar, click here.

This session will review the upcoming changes to the OASIS-E2 data set, including new and revised items and updates to the guidance manual. It will also address the ongoing “All-Payer OASIS Collection and Submission” mandate that took effect in 2025 and discuss the developments that have followed. In addition, the webinar will provide an overview of the 2026 Value-Based Purchasing OASIS-based measures, helping participants understand the key performance areas that most directly impact quality outcomes and reimbursement.

HPS stands ready to assist you with OASIS or any other clinical documentation. Please don’t hesitate to reach out to us.

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