What Changed in OASIS-E2: A Home Health Guide

OASIS-E2 Is Here. What Changed?

OASIS-E2 is the latest version of the Outcome and Assessment Information Set, released by CMS for Medicare-certified home health agencies. It took effect April 1, 2026, and builds on OASIS-E (effective January 1, 2023) and OASIS-E1 (effective January 1, 2025). CMS calls it a minor revision: one item removed, three items replaced or modified, three items added to Resumption of Care, and a set of coding tips pulled from the quarterly OASIS Q&As.

If you’ve already implemented OASIS-E1, OASIS-E2 is iterative, not a rewrite. Your workflows, EMR forms, and QA processes need targeted updates. The time points, M-item architecture, Section GG, and the PDGM functional items are preserved.

This guide walks through what changed, what didn’t, and what your agency should do. For the complete reference, see the What Is OASIS-E2 hub guide, the item-by-item OASIS-E2 changes page, and the OASIS-E2 Item Guide.

What Stayed the Same

OASIS-E2 preserves:

• Time points: Start of Care (SOC), Resumption of Care (ROC), Follow-up (including Recertification), Transfer, Discharge, and Death at Home
• M-item structure across clinical, functional, and service utilization domains
• Section GG self-care and mobility activities and the 6-point scale
• PDGM functional items: M1800-M1860 and M1033 keep their response options
• Diagnosis items: M1021 and M1023 coding and symptom control ratings
• Home Health Quality Reporting Program (HH QRP) submission via iQIES

Your clinicians already know the OASIS workflow. OASIS-E2 asks them to learn a short list of item changes.

What Changed: The 5 Categories of Updates

1. One Item Removed: O0350 COVID-19 Vaccination

CMS removed O0350 Patient’s COVID-19 Vaccination Is Up to Date. OASIS-E1 added it to support a quality measure, and the CY 2026 final rule removed the measure and the item together.

2. Items Replaced: A1255 Transportation and A0810 Sex

• A1250 Transportation became A1255 Transportation. The question now asks whether, in the past 12 months, a lack of reliable transportation kept the patient from medical appointments, meetings, work, or getting things needed for daily living. Codes are 0 Yes, 1 No, 7 Patient declines to respond, and 8 Patient unable to respond. A1255 is collected at SOC and ROC only. CMS dropped the Discharge time point.
• M0069 Gender became A0810 Sex. The manual notes no change in the data element.

Clinician training implication: if the patient declines A1255, code 7 and do not fall back on a proxy or the record. Use the record only when the patient cannot respond and no proxy answers.

3. Items Added to Resumption of Care

A1110 Language, B0200 Hearing, and B1000 Vision are now collected at ROC as well as SOC. Update ROC templates and remind clinicians to complete them on every resumption.

4. Falls: J1900 and a New Fall Definition

• J1900 Number of Falls now describes injuries with “includes but is not limited to” examples. Major injury lists traumatic fractures, dislocations and subluxations, internal organ injuries, amputations, spinal cord injuries, head injuries, and crush injuries.
• Pathological fractures confirmed as pathological are not a major injury from a fall.
• External force: in J1800 and M1033, a fall caused by an overwhelming external force now counts as a fall. OASIS-E1 excluded it.
• Balance training: an anticipated loss of balance during supervised balance training is not a fall, unless a fall or intercepted fall causes a major injury.

Why this matters for payment: M1033 Risk for Hospitalization is one of the eight PDGM functional items, so the new fall definition reaches the functional impairment level.

5. Guidance Pulled From the OASIS Q&As

CMS folded Q&A guidance into the manual. Highlights:

• Section GG: a clinician’s presence to complete the assessment is not automatically supervision. A ramp or elevator does not substitute for steps.
• M1840 Toilet Transferring: incontinence on the way to the toilet counts only if it affects the ability to get there and transfer safely.
• M1311 and M1340: a pressure ulcer treated surgically with a graft is a surgical wound until healed.
• Pain and mood: revised J0510-J0530 pain interview and D0150/D0160 PHQ instructions.
• Administrative items: new tips for M0030, M0032, M0090, M0100, M0150, M1000, M1018, and M2420.

What Did Not Change: SDOH

The CY 2025 final rule adopted four social-needs items: Living Situation (R0310), two Food items (R0320A and R0320B), and Utilities (R0330). The CY 2026 final rule removed them before collection began. OASIS-E2 has no housing, food, or utilities items. The GG discharge goal is also gone, but that change came earlier, with OASIS-E1 in January 2025.

For a side-by-side breakdown, see the OASIS-E1 vs OASIS-E2 comparison guide.

What QA Teams Need to Update

• Remove O0350 from forms and edit checks
• Swap A1250 for A1255 and drop it from Discharge
• Swap M0069 for A0810
• Add A1110, B0200, and B1000 to ROC templates
• Update fall rules for J1800, J1900, and M1033
• Remove leftover GG discharge goal fields from templates built for OASIS-E
• Keep documentation-to-OASIS cross-validation, because responses the narrative does not support are a common audit finding

For automated QA that flags OASIS-E2 inconsistencies so your QA team corrects them, see Lime’s AI-powered OASIS Review.

How OASIS-E2 Affects PDGM Payment

The PDGM functional impairment level comes from points on M1800-M1860 and M1033, not Section GG. The clinical group comes from the principal diagnosis on the claim, and the comorbidity adjustment from the secondary diagnoses. OASIS-E2 did not change the response options for any PDGM functional item.

The E2 change with payment reach is the new fall definition in M1033. Separately, CMS recalibrates functional points, thresholds, and case-mix weights every January through rulemaking, which shifts payment on its own schedule.

During your first months on OASIS-E2:

• Compare average PDGM payment per 30-day period to your pre-E2 baseline
• Identify clinicians whose functional scoring shifts sharply in M1800-M1860 or M1033
• Run focused QA on M1033 fall coding and M1800-M1860 scoring during the first 30 days
• Give just-in-time feedback on scoring drift before patterns set in

The 90-Day OASIS-E2 Transition Plan

Here’s the high-level rollout for a typical agency:

1. Week -8: Capture baseline metrics (PDGM payment, error rates, time-to-completion)
2. Week -6: Confirm the EMR vendor OASIS-E2 form push timeline
3. Week -4: Update written OASIS policies and QA rule sets
4. Week -3: Begin clinician training on OASIS-E2 changes (see the 90-day training plan)
5. Week 0: OASIS-E2 effective date, clinicians complete first assessments with QA co-signing
6. Weeks 1–4: Daily QA huddles, weekly PDGM payment monitoring
7. Weeks 5–12: Move to weekly QA review and complete competency validation
8. Week 13: Full independent practice, with quarterly internal audits

For the complete agency rollout playbook, see the OASIS-E2 Implementation Playbook.

How AI Reduces the OASIS-E2 Transition Risk

Even with strong training, clinicians make OASIS-E2 errors, especially in the first 60 days. OASIS Scribe reduces transition risk by:

• Drafting OASIS-E2 responses from the natural visit conversation, so clinicians review and confirm every final response rather than type from scratch
• Real-time flags when responses look inconsistent, so your QA team corrects them before submission
• PDGM-aware checks on M1800-M1860 and M1033
• Prompts for skipped items, including A1255 at SOC and ROC
• Direct EMR sync to HCHB, WellSky, MatrixCare, Axxess, and DSL, no double entry

Lime reports a 75% reduction in documentation time and 95% accuracy.

Authoritative Source: The CMS OASIS-E2 Guidance Manual

For binding item-level guidance, always reference the CMS OASIS-E2 Guidance Manual on cms.gov. Appendix D lists every change from OASIS-E1. CMS also posts quarterly OASIS Q&As, so give your QA team a process to review CMS updates and refresh internal SOPs.

What to Do This Week

1. Read the What Is OASIS-E2 hub for the framework overview.
2. Download the CMS OASIS-E2 Guidance Manual and distribute it to all OASIS-completing clinicians.
3. Capture baseline metrics: average PDGM payment per 30-day period, OASIS error rate, and time-to-completion.
4. Check your EMR templates for O0350, A1250, M0069, and any GG discharge goal fields.
5. Book a 25-minute call with the Lime team to see how AI drafts documentation and flags QA issues during the transition.