Home Health OASIS Submission: Your QAO Report Is Out, the 90% Threshold Decides 2 Points, and the December 31, 2026 Cutoff Is Final

CMS posted home health agencies' Annual Quality Assessment Only (QAO) performance reports to iQIES on September 18, 2026 — and any agency below 90% on that report is looking at a 2-percentage-point cut to its Medicare payment update. The report covers OASIS assessments completed July 1, 2025 through June 30, 2026. At the same time, a separate hard stop is approaching: assessments dated January 1, 2025 through March 31, 2026 are accepted only until December 31, 2026, and the manual-entry screen that small agencies used to catch up was retired on April 1. This post explains what the QAO report measures, what the penalty costs, and a 90-day plan to close any gap.

Key Takeaways

• The Annual QAO performance report was made available in iQIES folders on September 18, 2026, covering assessments completed 7/1/2025–6/30/2026 and submitted by August 5, 2026.
• CMS requires a QAO compliance rate of 90% or more, regardless of payer.
• Agencies that miss the reporting requirement take a 2-percentage-point reduction to the home health market basket update, under section 1895(b)(3)(B)(v)(I) of the Social Security Act.
• QAO reports stay in iQIES folders for 120 days — download and save yours now.
• All-payer OASIS collection and submission has been mandatory since July 1, 2025.
• CMS discontinued the legacy iQIES manual data-entry interface on April 1, 2026; submissions must come from a certified system or approved file format.
• Assessments dated 1/1/2025–3/31/2026 will be accepted only until 12/31/2026.
• The next Care Compare refresh is October 21, 2026; the deadline for missing or corrected data for that refresh was May 15, 2026.

What the QAO Report Measures

CMS calls it the "Quality Assessments Only" formula because only OASIS assessments that contribute, or could contribute, to creating a quality episode of care are counted. Agencies must reach a 90% or higher compliance rate on that metric.

The reporting calendar

The annual report is the one that counts for the payment determination. The interim reports were the warning shots. If your agency never opened them, open the annual report this week.

Why all-payer matters here

Since July 1, 2025, OASIS must be collected and submitted for every skilled patient regardless of payer. The QAO requirement is 90% regardless of payer source. An agency that treated Medicare Advantage or private-pay OASIS as optional after July 2025 may have pulled its compliance rate down without noticing.

What Missing 90% Costs

The penalty is applied to the payment update, which means it hits every Medicare fee-for-service dollar for the year, not only the episodes with missing data.

Illustrative example

An agency with $5 million in annual Medicare fee-for-service revenue that takes the 2-point reduction would receive roughly $100,000 less that year than it otherwise would ($5,000,000 × 2%). This is illustrative; the actual effect depends on your case mix, wage index, and volume. For most small agencies, that is more than the annual cost of fixing the submission process.

Reconsideration

If you believe a determination is wrong, CMS's reconsideration page says requests must be sent within 30 days of receiving a non-compliance notice. Separately, exception or extension requests for extraordinary circumstances such as disasters must be filed within 90 days of the event. Both go to CMS by email, and CMS asks that no patient data be included. Build your file from contemporaneous evidence — iQIES final validation reports, EMR export logs, and dated correspondence — not from memory.

The December 31 Cutoff for Older Assessments

This is a separate problem from the QAO score. CMS retired the browser-based iQIES data-entry screen on April 1, 2026, the same day OASIS-E2 took effect. Agencies with a backlog of unsubmitted assessments from 2025 or early 2026 now have one path — a correctly formatted file from a certified system — and one deadline.

Agencies that changed EMR vendors in 2025, started operations mid-year, or relied on manual entry as a fallback when exports failed are the most exposed.

A 90-Day Submission Plan

October

• Download and save the Annual QAO report and the three interim reports.
• Pull an exception list of every assessment dated 1/1/2025–3/31/2026 without an accepted submission, reconciled to iQIES final validation reports — not just the EMR status field.
• Test an export of one old record end to end before attempting the batch.

November

• Submit the backlog in batches and clear rejections the same week.
• Confirm non-Medicare OASIS since July 1, 2025 is being submitted.
• Reconcile assessment counts to billed 30-day periods; every period should have an assessment.

December

• Final sweep of rejections by December 15, leaving margin before the cutoff.
• Document anything you could not fix, with evidence, in case you need reconsideration.

Reconciling assessments to billed periods belongs in the monthly close, not the year-end scramble. It is standard in the bookkeeping services we run for Medicare-certified agencies, because the same visit and period statistics feed your Medicare cost report filing and the MAC tests them against claims.

The Bottom Line

Two OASIS clocks are running. The QAO report posted September 18 tells you whether you cleared 90% for the payment determination; the December 31 cutoff decides whether your 2025 and early-2026 backlog counts at all. Open the report, save it before the 120 days run out, and work the exception list through October and November. If you are not sure what your submission gap looks like, schedule a free consultation while there is time to close it.

Sources

• CMS, Home Health Quality Reporting Data Submission Deadlines (page last modified July 1, 2026)
• CMS, Home Health Quality Reporting Requirements
• CMS, Home Health QRP Spotlight and Announcements
• CMS QTSO, OASIS iQIES Software Discontinuation
• CMS, Home Health Quality Reporting Reconsideration and Exception & Extension

Last updated: September 2026.

Soriaga & Associates, LLC is a CPA firm specializing in home health, hospice, and home care accounting and Medicare cost reports.