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What CMS says about AI in home health documentation

CMS issues clear guidance in the OASIS E2 manual on the role of AI in clinical documentation.

Tiantian Zha
Tiantian ZhaCo-founder, Andy
PublishedSeptember 9, 2026
UpdatedSeptember 9, 2026

Until recently, CMS guidance on the use of AI in home health has been patchy at best. Fortunately, the OASIS E2 update provides clear guidance: AI is permitted, with firm guardrails.

What CMS says about AI and the OASIS

The OASIS-E2 Manual states that: while AI may be used to assist clinicians in assessing the patient, the human is ultimately responsible for the accuracy of the final answer.

Here’s a direct quote from CMS (emphasis ours):

An agency’s software may not “answer” or “generate” a final code for the OASIS 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

The specific phrase final code and clinician responsibility clarifies that a clinician is ultimately responsible for accuracy. In their April Q&A, CMS restates this same position in response to a specific question about ambient AI:

Question 1: A clinician is completing a Start of Care assessment. Their iPad uses an ambient listening AI platform, with the patient’s consent, that populates some of the OASIS responses while the assessment is being conducted. After completing the assessment, the clinician reviews the OASIS items one by one, making corrections on any items they feel were incorrectly coded by the AI platform.

Answer 1: As stated in the final version of the OASIS-E2 Guidance Manual, “an agency’s software may not “answer” or “generate” a final code for the OASIS 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.”

Changes from the draft to the final OASIS manual

The evolution of the CMS guidance all reflect the same underlying principle that while AI tools may assist, clinicians are ultimately responsible for the final accuracy.

The draft manual left things vague:

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

Between the publication of the draft and final version, CMS clarified 2 things. First, that the software may not generate the final OASIS response:

An agency’s software may not “answer” or “generate” a final code for the OASIS items.

Second, that clinicians are responsible for verifying the correct response was entered, however the initial responses were entered in the first place.

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

QA and collaboration in finalizing OASIS scores

The guidance around AI builds on existing principles of collaboration with other professionals to gather information for OASIS items.

The manual explicitly allows collaboration with the patient’s family members, caregivers, other health personnel, whether they’ve had direct contact with the patient, or have other ways to understand the patient’s situation.

While only the assessing clinician is responsible for accurately completing and signing a comprehensive assessment, they may collaborate to collect data for all OASIS items … [with] other health care personnel, including the physician, pharmacist, and/or other agency staff who have had direct contact with the patient or had some other means of gathering information to contribute to the OASIS data collection.

How AI vendors can support or hinder human review

Saying that humans must review every answer is not the same as designing a system that encourages clinician participation.

A tool shouldn’t block or discourage clinicians from viewing OASIS responses. It also shouldn’t raises too many flags to create notification fatigue.

In an ideal world, it can intelligently direct a clinician’s attention to the most important areas requiring review.

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