Clarice Grote, MS, OTR/L

Clarice Grote, MS, OTR/L

Can Occupational Therapists Perform the SOC OASIS?

*Information updated on November 16, 2021 to reflect the new Medicare rules*

Can occupational therapists initiate the OASIS Start of Care? Yes!

The question is…

  • How do we spread the word? and
  • Under what circumstances can OTs initiate the OASIS?

Podcast: HH OASIS & Value-Based Purchasing

Non-Medicare Patients Receiving Home Health

Can occupational therapists initiate the OASIS Start of Care for non-Medicare patients? It depends.

Private health insurance and Medicaid have their own rules about who can and cannot initiate the OASIS Start of Care and under what circumstances. The best thing to do in this scenario is to consult Medicaid and private insurer regulations. Keep in mind regulations may change with recent Medicare changes. So, if OTs previously couldn’t initiate and complete the OASIS Start of Care, it would be worth rechecking the guidelines.

Still no change? It sounds like a time for advocacy!

Medicare Patients Receiving Home Health Under Part A

Until recently, occupational therapists have been unable to initiate the OASIS in any situation. However, the Centers for Medicare and Medicaid Services (CMS) issued changes to the rules under the Public Health Emergency (PHE).

Under the COVID-19 PHE, CMS issued a special waiver allowing occupational therapists, physical therapists, and speech-language pathologists could initiate the OASIS Start of care for Medicare Part A patients in ALL cases. This waiver will expire when the PHE ends. This temporary waiver intends to help relieve some of the responsibility on nurses.

After many years of advocacy, we had a HUGE win for home health. The language Medicare Home Health Flexibility Act was signed into law in December 2020 as part of the Consolidated Appropriations Act of 2020 after advocacy from AOTA and OT Advocates.

This legislation required CMS to develop a permanent rule change to allow OTs to initiate and complete the comprehensive start of care assessment in therapy-only cases. Therapy-only cases are when skilled nursing is not included on the initial home health order.

In June 2021, CMS released the proposed rule change to allow OTs to initiate the OASIS in therapy-only cases permanently, and the final rule was released in November 2021. The new law was implemented on January 1, 2022. So, once the PHE ends, this law will permanently be in effect.

Some agencies were hesitant to allow OTs to initiate the OASIS due to the public health emergency flexibility being temporary. This hesitance was primarily due to concerns there may be a gap between the end of the PHE and the start of this rule. However, we now know there will not be any gap between the end of the PHE and the start of the new law. So, that hesitancy should no longer be an issue.

Of note, as long as the PHE is in place, OT will continue to be able to initiate and complete the comprehensive assessment in all cases.

OTs will permanently be able to initiate the OASIS Start of Care in therapy-only cases for Medicare Part A patients effective January 1, 2022.

Advocating for occupational therapists to initiate the OASIS

Occupational therapy practitioners must take it upon themselves to educate home health agencies on the change in regulation. Remember that you may need to speak to multiple people and make multiple attempts before success.

Tips for educating your employer:

  • Do your research.
  • Be prepared to answer questions.
  • Bring evidence such as this article, AOTA articles, or the CMS final CY 2022 rule change.
  • Identify that the final rule is only for therapy-only cases.
  • Identify why OT is the perfect profession to initiate the OASIS.
    • experts in function
    • experts in functional cognition
    • skilled in assessing and incorporating multiple elements in an evaluation such as social determinants of health
  • Identify how OT can improve accuracy on functional limitation reporting which directly impacts reimbursement under PDGM. Accurate scoring also helps agencies meet quality outcomes with accurate admit and discharge scoring.

What if your employer says no:

What if you or other OTs don’t want to do the OASIS?

  • Discuss the pros and cons.
  • Acknowledge income/pay concerns and discuss strategies to advocate for change.
  • Identify concerns over low caseload due to other disciplines canceling OT orders – this won’t happen if OT opens the case.
  • Offer to provide education on how to complete the OASIS.

This change is great news for occupational therapy in home health and helps ensure the longevity of OT in this setting. Some agencies have resisted hiring OTs full-time due to concerns that OTs cannot do all the necessary job elements as a PT can. However, we are now able to combat this assumption. Remember, if you don’t advocate for OT, who will


Clarice standing in a light room smiling wearing black pants and a light green puff sleeve shirt

hi there,

I’m  Clarice

Occupational therapist & medicare specialist helping practitioners understand policy, engage in advocacy, and own their value!

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