Home health compliance in 2025 is becoming more demanding as agencies face a complex regulatory landscape. Medicare is rolling out the updated OASIS-E1 assessment, expanding its Home Health Value-Based Purchasing (HHVBP) model nationwide, and requiring strict Electronic Visit Verification (EVV) compliance per the 21st Century Cures Act. At the same time, national interoperability standards (like TEFCA) are coming online. This guide breaks down the key compliance deadlines and interoperability updates for 2025 – and offers action steps to keep your agency ahead of the curve.
2025 Key Home Health Compliance Updates
- Payment Update: CMS finalised a 0.5% increase to the 2025 Home Health Prospective Payment System. (This reflects a +2.7% market basket minus a 2.2% productivity adjustment.) Home health agencies will see roughly $85M more in total payments than in 2024. Note: Even with this bump, agencies must validate claims meticulously to avoid denials. (source: American Speech-Language-Hearing Association)
- Quality Reporting: CMS is adding standardised patient assessment items related to social determinants of health (SDOH), finalising four new SDOH elements for reporting by 2027. (No immediate QRP penalties in 2025, but prepare for data collection changes.) (source: Federal Register)
- Conditions of Participation (CoPs): A new Acceptance-to-Service policy is required. CMS now mandates that HHAs establish clear, written criteria for accepting patients to ensure agencies only enrol patients whose needs they can meet. Agencies must also publicly disclose their service capabilities.
- Home IVIG: If applicable, updated payment rates for home infusion therapies (like IVIG) were set in the final rule (mostly technical updates).
- Other: No major changes to Therapy reassessment thresholds or late-payment adjustments beyond the above; however, agencies should continue monitoring CMS memos for any late corrections (e.g. the All-Payer OASIS transition guide is being posted in early 2025).
Each of these updates demands careful review for any agency prioritising home health compliance in 2025. Ensure your compliance officers and IT staff understand how documentation, billing rules, and patient notice requirements may shift this year.
OASIS-E1 Changes (Effective Jan 1, 2025)
CMS has finalized the new OASIS-E1 assessment instrument – effective January 1, 2025. All home health agencies must switch to OASIS-E1 for start-of-care (SOC) and recertification assessments on or after 1/1/25. Key changes include:
- New and Removed Items: The only new item added is O0350 (COVID-19 vaccination status). Agencies must record if a patient’s COVID-19 vaccine is up to date. Conversely, CMS removed item M0110 (Episode Timing) and M2200 (Therapy Need) from HHQRP, since they’re no longer used. Minor instruction tweaks also apply to functional items (e.g. GH0130/GG0170 revisions). (source: HHL)
- Access to Final Manual: The final OASIS-E1 manual and change table were released Dec 2024 and can be downloaded from the CMS OASIS User Manuals page. We recommend reviewing these documents now. CMS confirms that the official OASIS-E1 guidance is available for agencies in the Downloads section (source: CMS).
- Vendor/EMR Updates: Ensure your EHR/OASIS software is upgraded. Many EMRs have already released OASIS-E1 templates; check that your vendor is fully compliant. Training for nurses and therapists on the new item changes (especially the COVID vaccination question) is critical.
Action: Update intake workflows now to capture the new vaccine item and remove deprecated fields. See the OASIS User Manuals (CMS) page for the final OASIS-E1 Guidance Manual.
HHVBP 2025: Expanded Value-Based Purchasing
CMS’s Home Health Value-Based Purchasing (HHVBP) model is expanding nationwide. Now renamed the Expanded HHVBP Model, it includes all 50 states (plus DC and territories) as of 2022. Important points for 2025:
- First Payment Year (2025): Agencies’ CY2025 Medicare payments will be adjusted based on performance in CY2023. That means your 2023 quality scores (claims-based measures, HHCAHPS survey, and OASIS-based measures) will translate into pay adjustments in 2025 (ranging from 5% to +5% of Medicare FFS payments) (source: cms.gov).
- Performance Measures: While CMS hasn’t added any new HHVBP measures in the 2025 final rule, it did solicit input via an RFI on future measure concepts. Agencies should continue improving existing measure performance (hospitalisations, functional status changes, patient experience) to maximise their score. CMS will likely continue surveying HHAs on potential new measures (e.g. communication, cognition) to inform future years.
- HHCAHPS Updates: CMS plans to shorten the HHCAHPS survey based on 2022 field tests. Prepare for a possibly updated patient survey in late 2025 or beyond. For now, continue collecting patient experience data diligently (the 2023 HHCAHPS results will feed into 2025 payments).
Bold Callout: Home Health agencies must proactively monitor their IPR reports and claims data for HHVBP scoring. Consider partnering with analytics vendors or using internal BI tools to project your likely 2025 adjustment. Start planning quality improvement initiatives now.
(Internal link opportunity: Promote your expertise or content on quality performance or AI-driven analytics. For example, see our Healthcare AI solutions page on predictive analytics and quality improvement.)
EVV Compliance: State-by-State Mandates
Under Section 12006 of the 21st Century Cures Act, all states must implement Electronic Visit Verification (EVV) for Medicaid-funded home health and personal care services. The deadlines have come into force:
- Medicaid Deadline: Most states had to achieve full EVV compliance by January 1, 2023 or 2024 (with a few allowed delays). CMS requires states to self-certify EVV readiness, and by January 1, 2024 nearly every state reported some compliance status. The CMS “EVV Compliance Status” table shows which states are fully compliant (e.g. all 1/1/24) versus partial or not compliant as of early 2024 (source: medicaid.gov).
- Home Health Agencies: If your agency bills Medicaid in any state, EVV is now mandatory. EVV systems must capture the six data elements (who, what, when, where, start/stop times, and purpose) for every Medicaid home health visit. Ensure your EVV vendor/system is up-to-date and integrated with your scheduling and billing systems. Failure to comply can result in payment reductions at the state level.
- Private Pay and Medicare: Note that EVV mandates technically apply only to Medicaid. However, some states may extend EVV-like requirements to all home health services. Also, CMS encourages the use of EVV data for care coordination. Regardless, consider adopting EVV for Medicare home visits, too – it can improve accountability and data quality.
Action: Audit your EVV processes in Q1 2025. Verify each Medicaid state’s EVV rules (including any recent waivers). Provide training or resources to field staff on using EVV devices/apps. (For example, see CMS’s EVV guidance on State EVV implementation.)
Interoperability & TEFCA: Data Exchange Readiness
Interoperability expectations are rising. Home health agencies must ensure secure, timely data exchange with hospitals, doctors, and other providers. In particular, the ONC’s TEFCA initiative is now live:
- TEFCA Network: In December 2023, ONC’s RCE (The Sequoia Project) officially designated the first Qualified Health Information Networks (QHINs). In practical terms, this means nationwide network-to-network exchange is coming online. Several large networks (e.g. eHealth Exchange, Epic Nexus) are now “live” QHINs. (source: sequoiaproject.org). TEFCA’s goal is to create a “network of networks” so that providers can share health data across states and systems.
- FHIR and APIs: TEFCA strongly encourages the use of HL7 FHIR APIs for data exchange. Home health agencies should plan to implement patient data APIs and join a health information network. This aligns with CMS’s policies in the ONC/HIT final rules (requiring standardized APIs). By 2025, your EHR should be capable of sending ADT and CCD data via standardized protocols.
- Business Case: Interoperability isn’t just regulatory – it’s strategic. Exchanging data (e.g. sending care summaries to PCPs or receiving hospital discharge notices) can improve outcomes and reduce readmissions. In the VBP era, having a connected platform can directly impact your quality scores.
Bold Tip: Start with smaller steps: connect to your state’s HIE or a vendor HIN that is TEFCA-ready. Evaluate integration partners (our Integration & Middleware services can help) to build FHIR-based interfaces. Emphasize interoperability projects in your 2025 roadmap.
Action Plan: Steps for 2025 Compliance
To summarize, here are the key actions home health leaders should take now:
- Upgrade OASIS Workflows: Implement OASIS-E1 in your EHR, train staff on new data items (COVID vax status), and retire old fields. Review the final OASIS-E1 manual (source: cms.gov) and ensure forms are updated.
- Monitor HHVBP Metrics: Use your Q4 2024 data to benchmark 2023 performance. Focus on functional outcomes and patient experience. Engage clinical teams on discharge planning and patient satisfaction to boost future scores.
- Check EVV Systems: Confirm EVV vendor compliance in all states of operation. Run end-to-end tests of clock-in/clock-out capture and billing integration. Provide ongoing EVV training and support for field staff.
- Implement Interop Solutions: Meet TEFCA readiness by enabling standards-based exchange. For example, enable QR codes or FHIR-enabled patient records. Align with hospital partners: ask what EHR interfaces they need for sending POC or receiving referrals.
- Leverage Technology: AI and Automation can help compliance. Consider advanced billing/Coding engines to validate claims against PDGM and OASIS rules, reducing denials. (See our [AI Development][2] and [Intelligent Automation][6] services for examples.)
- Review CoPs: Draft or update your acceptance-to-service policy and publicly post service offerings. Audit your enrollment verifications and home health patient notice procedures per CMS’s updated guidance.
Future Proof Your Agency with the Right Digital Strategy
2025 is not just another compliance year. It marks a shift in how home health agencies operate, with expanded HHVBP, mandatory OASIS-E1 updates, EVV enforcement, and rising interoperability expectations through TEFCA. Agencies that treat this as a checklist exercise will fall behind. Those who see it as an opportunity to modernize will lead.
At Copper Digital, we partner with home health providers to turn compliance challenges into strategic wins. Whether it’s building FHIR-based data exchange, automating quality reporting and analytics, or integrating AI tools for documentation and claims accuracy, we design solutions that improve care and drive performance.
If your agency is looking to stay compliant, connected, and competitive in home health compliance 2025, we’re ready to help. Let’s build a digital roadmap that supports your team, your patients, and your long term growth.
Start planning today with Copper Digital. Your compliance advantage begins here.
