The short answer
No independent study or CMS data compares OASIS-E2 documentation speed across different home health software platforms. All major EMRs (WellSky, Homecare Homebase, Axxess, MatrixCare, AlayaCare, KanTime, and others) updated to support OASIS-E2 by the April 1, 2026 implementation deadline. The documentation burden that nurses describe—spending one to two hours on start-of-care forms, and facing claim denials from inconsistent scoring—appears consistent across platforms because the challenge is the federal requirement itself, not the software implementing it.
The problems operators describe
Inconsistent functional scoring creates a recurring problem. This happens because the comprehensive assessment window—no later than 5 calendar days after start of care—often does not align with when the nurse can sit down to complete the full form.
A nurse can document a patient as independent in ambulation while simultaneously documenting wound care requiring full assistance, and the system accepts both. The mismatch only surfaces during pre-billing review or an additional documentation request.
Federal deadlines and requirements
OASIS-E2 applies to assessments with M0090 (Date Assessment Completed) on or after April 1, 2026. The M0090 date is the last date that information used to complete the comprehensive assessment was gathered, which determines the OASIS version to use. The comprehensive assessment must be completed no later than 5 calendar days after the start of care, and the initial assessment visit must be held within 48 hours of referral, within 48 hours of the patient's return home, or on the physician-ordered start of care date.
Recertification assessments must be completed during the last 5 days of every 60-day period beginning with the start-of-care date. If a patient returns from a hospital admission of 24 hours or more, a resumption-of-care assessment is due within 48 hours.
| Assessment Type | Completion Window | Notes | |-----------------|-------------------|-------| | Initial visit | Within 48 hours of referral or return home | Or on physician-ordered start date | | Comprehensive assessment | Within 5 calendar days of start of care | Includes all OASIS items | | Recertification | Last 5 days of each 60-day period | Begins with start-of-care date | | Resumption of care | Within 48 hours of return from hospital | Only if hospital stay was 24+ hours | | Discharge | Within 2 days of discharge date | Requires in-person encounter | | Submission to CMS | Within 30 days of M0090 date | Via iQIES |
Who can complete the assessment
A registered nurse must complete the comprehensive assessment and determine Medicare eligibility, including homebound status. The one exception is when physical therapy, speech-language pathology, or occupational therapy is the only service ordered by the physician—in that case, a physical therapist, speech-language pathologist, or occupational therapist may complete it.
The all-payer mandate starting July 2025
Effective July 1, 2025, OASIS data collection became mandatory for all patients regardless of payer source. Previously, OASIS applied primarily to Medicare and some Medicaid patients. Now agencies must collect and submit OASIS for patients with any pay source who are not specifically exempt and who begin receiving services with a start-of-care date on or after July 1, 2025.
How this applies across states
OASIS requirements apply uniformly across all states for Medicare-certified home health agencies. The OASIS regulations apply to any agency that must meet the home health Medicare Conditions of Participation. If an agency is Medicare-certified under federal or state law, it must meet the Conditions of Participation related to OASIS and the comprehensive assessment.
State variations apply to licensing and staffing, not to OASIS itself. For example:
- California: On June 26, 2025, the California Department of Health issued a provider letter outlining changes in the application process effective July 1, 2025, including application fees and denials of incomplete licensing packets.
- Florida: House Bill 1353 updated home health licensure regulations effective July 1, 2025, affecting administrator requirements, nursing workforce requirements, and an Excellence in Home Health program.
- Texas: There is no state license or certification of home health aides, but Medicare-certified agencies must provide or supervise 75 hours of training for home health aides, with at least 16 hours of classroom training completed before beginning 16 hours of supervised practical (clinical) training. Texas agencies must transmit OASIS information within 30 days of completing the assessment, the same as the federal standard.
The submission deadline, assessment windows, and item-level requirements do not vary by state.
What agencies commonly get wrong
Falls documentation: According to the 2023 OIG report, 55% of falls with major injury identified in Medicare claims were NOT reported in OASIS assessments. The expanded guidance in OASIS-E2 makes the expectation clear: every fall counts, including outside the home.
Relying on the patient for diagnosis confirmation: You must have physician documentation or verbal confirmation of a diagnosis in order for it to be coded. Patient statements alone are not sufficient.
Using the patient's requested start-of-care date: The start-of-care date must come from the physician, not the patient.
Misunderstanding "day of the assessment": OASIS item coding is based on the patient's status during the 24-hour period directly preceding the assessment visit, plus the time the clinician is in the home conducting the assessment. This is not the same as the calendar day of the visit.
Missing the discharge assessment deadline: Agencies sometimes treat the discharge assessment as optional or administrative. It requires an in-person patient encounter within two days of the discharge date.
Why speed claims are hard to verify
Vendor blogs and software review sites claim that certain platforms complete OASIS assessments in "30 to 45 minutes" or "under 10 minutes with AI-native systems." These claims do not cite independent studies, CMS data, or operator time logs. The time required depends on patient complexity, the nurse's familiarity with the patient, whether the visit is start of care or recertification, and how much of the assessment can be completed during the visit versus afterward.
What the regulations do not specify
The Conditions of Participation do not specify:
- Which brand of software to use
- How the software should organize the OASIS items on screen
- Whether voice-to-text, templates, or pre-fill logic are allowed (they are, as long as the final submission is accurate)
- How much of the assessment must be completed during the visit versus afterward
Agencies have discretion in workflow design, as long as the final comprehensive assessment is completed within 5 days, transmitted within 30 days, and reflects accurate clinical findings.
The approval and expiration timeline
The OASIS-E2 instrument carries OMB control number 0938-1279 and an expiration date of December 31, 2028. This means CMS has federal approval to collect this data through the end of 2028, after which the instrument will be reviewed and potentially revised again.
What this means for software selection
If documentation speed is your primary concern, the question is less about which EMR you choose and more about:
- Training consistency across your clinical team
- Supervisory review processes that catch errors before submission rather than after denial
- Workflow design that allows nurses to complete as much as possible during the visit
- Internal validation rules that flag inconsistent scoring before the form is finalized
All major platforms updated to support OASIS-E2 by April 2026. None publish third-party-verified time studies showing faster completion than competitors. The burden described by operators appears rooted in the federal requirement, which is the same regardless of software.
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