What did OASIS-E2 change in 2026, and what does an administrator do about it?

E2, in effect since April 1, 2026, is still the current OASIS version. Section 1.4 of the E2 Guidance Manual says the COVID-19 vaccination item was removed "to align with removal of the associated quality measure." It adds that the new transportation item "will only be collected at SOC/ROC." Appendix B of the manual tags every item with its uses: administrative, quality, risk adjustment, payment under PDGM, or payment under HHVBP.

A risk adjustment tag means CMS may use the answer to account for how sick or limited your patients were when it compares your results with other agencies'. It isn't a payment tag: Appendix B lists PDGM payment and HHVBP payment as tags of their own.

Upper body dressing (M1810), lower body dressing (M1820) and bathing (M1830) are the only items Appendix B tags for both PDGM and HHVBP payment, so the same answers can feed your payment group and your HHVBP score. The PDGM tag also sits on grooming (M1800), toilet transferring (M1840), transferring (M1850), ambulation (M1860) and risk for hospitalization (M1033), the other items behind your PDGM functional score.

Other items with the HHVBP tag include shortness of breath (M1400), management of oral medications (M2020), discharge disposition (M2420), the primary diagnosis (M1021) and several GG self-care and mobility items, such as eating, sit to stand and walking 10 feet.

Many of the same answers feed your star rating. Five of the seven quality star measures are improvement in ambulation, bed transferring, bathing, shortness of breath and management of oral medications. Matching each measure to an OASIS item by name is our reading; CMS's star ratings page doesn't map them.

Since July 1, 2025, you've submitted OASIS for every skilled patient whose start of care assessment is dated (M0090) on or after that day, private-pay and commercial included. The exemptions stayed the same: under 18, maternity care, and personal care, housekeeping or chore services only.

CMS's all-payer fact sheet says it "has not announced if, when or how" it will use the other payers' data in HHVBP.

For your annual payment update, 42 CFR 484.245 sets the bar at "90 percent of all required OASIS or successor instrument records" each year. Miss it and your update drops 2 percentage points. The update CMS issues in January 2027 uses July 1, 2025 through June 30, 2026, the first full all-payer year. In our reading, that's the first time a missing private-pay assessment counts against your 90%. CMS posted the annual performance report for that window in iQIES on September 18, 2026, and keeps these reports there for 120 days.

CMS issued the CY 2027 home health final rule (CMS-1844-F) on November 4, 2026, and the Federal Register published it on November 9. It adds and removes no OASIS item, and its paperwork section finds "no changes to expected burden associated with OASIS data collection."

For quarters through the end of 2026, you have about four and a half months after the quarter closes to submit and correct OASIS data. Starting with the first quarter of 2027, the rule requires submissions and corrections "no later than the 15th day of the second month after the end of the calendar quarter." When that date falls on a Friday, weekend or federal holiday, the deadline moves to the next business day. CMS found 99.27% of 2024 assessments already arrived within 45 days and expects 0.49% to be affected. CMS wants fresher public data: the nine-month gap between a quarter closing and public reporting could shrink by up to three months.

The rule lists 2027 quarters only. For July to December 2026, watch CMS's HH QRP data submission deadlines page, which still shows the 2025 schedule.

The payment-update year moves to the calendar year on January 1, 2027. The six months from July 1 through December 31, 2026 decide your 2028 OASIS payment update, and calendar 2027 decides 2029. Your HHCAHPS year moves too, with April 1 through December 31, 2026 as its transition.

Under 42 CFR 484.45(a), each completed assessment still goes to CMS "within 30 days of completing the assessment"; since the CY 2026 rule, the text says "each patient," not each beneficiary. You can still submit, modify or inactivate a record for 24 months from its target date. But a correction made after the quarterly deadline shows only in your own quality reports, not in Provider Preview Reports or on Care Compare.

In our read, most training time belongs on the items with a PDGM or HHVBP tag, because those answers feed your payment group or your HHVBP score. E2's own changes fit in a short session: the new transportation and sex prompts, the three items added at resumption of care, and the reworded fall answers. The manual asks agencies to train on data accuracy "on a continuing basis" and to monitor that what's transmitted "exactly reflects the data collected by the skilled professional."

The timing and sampling in this plan are our suggestions; CMS sets the deadlines and the 90% threshold.

1. Confirm your software is on E2. Check that resumption of care asks hearing, vision and language, and that A1255 and A0810 replaced the old items.
2. Save your annual performance report. Download the July 2025 to June 2026 report before its 120 days run out.
3. Count private-pay and commercial assessments. Compare skilled non-Medicare admissions since July 1, 2025 with accepted OASIS records in iQIES.
4. Check the double-tagged items. On a sample of discharges each month, check that dressing and bathing answers at start of care and discharge match the visit notes.
5. Move your QA cutoff. Finish internal review well before May 17, 2027 for first-quarter assessments, and clear the Review and Correct Report in iQIES before each deadline.

Enzo is a home health EHR.

Is OASIS-E3 coming?

Not on CMS's pages as of November 7, 2026. The data sets and user manuals pages list E2 as the latest version, with no draft of a later one.

Can we get an exception to the 90% bar?

You can ask when extraordinary circumstances beyond your control kept you from reporting, and CMS decides whether to grant it. Send the request by email to HHAPUReconsiderations@cms.hhs.gov within 90 days of the event (42 CFR 484.245(c)(2)). The rule also changes 42 CFR 484.245 so CMS sends its decision on any reconsideration request through its data submission system; the current text also allows mail or an email from your MAC.

Do private-pay assessments affect our star rating?

Not today. CMS's data submission deadlines page says OASIS-based measures are still calculated only for Medicare and Medicaid patients, managed care plans included, and that CMS will notify providers when it decides on other uses for the all-payer data.