As agencies prepare for the April 1, 2026 implementation of OASIS-E2, the Centers for Medicare & Medicaid Services (CMS) has released the final version of the OASIS-E2 Guidance Manual, along with updated instruments and supporting materials for the Home Health Quality Reporting Program.

Within that update, a small but meaningful revision in Convention #9 deserves attention—particularly for agencies using, or considering, AI-assisted documentation tools.

The draft manual previously stated:

An agency’s software may not “answer” or “generate” the OASIS response for the assessing clinician.

The final manual now states:

An agency’s software may not “answer” or “generate” a final code for the OASIS response items. Following agency policies, the assessing clinician is responsible for considering available information and ensuring the appropriate OASIS item response(s) were selected, within the appropriate timeframe and consistent with data collection guidance.

That single word — “final” — materially changes how this provision reads.

CMS appears to be drawing a clear line:

• Technology may assist with gathering information or suggesting responses
• Software may not determine the final coded response
• The assessing clinician remains accountable for the final OASIS item selection

With the rapid expansion of AI-supported documentation and coding tools, this clarification is notable. OASIS remains a clinician-driven assessment, and CMS continues to place responsibility for the final coding decision squarely with the licensed clinician completing the assessment.

The OASIS-E2 update, which replaces the current OASIS-E version, includes a number of additional revisions to the instrument and guidance materials. CMS has indicated that agencies should carefully review the updated manual and change tables before implementation, as the new guidance incorporates numerous technical clarifications and updates since the draft version was released in 2025.

Steps Agencies Should Consider Before April 1

Prior to the implementation date, agencies should consider the following steps:

• Review and update OASIS policies to clearly state that clinicians retain final coding authority
• Confirm documentation vendors are not auto-finalizing OASIS responses
• Ensure clinicians understand that software suggestions do not replace clinical judgment
• Be prepared to demonstrate how the agency maintains oversight and accountability

Small wording changes in CMS manuals can carry meaningful compliance implications. As always, careful review of CMS guidance—even seemingly minor revisions—is essential to maintaining regulatory compliance.

Questions about how this guidance may affect your agency’s OASIS processes can be directed to Colleen or Kim.