Home health agencies have lived with a July-to-June reporting cycle for OASIS and HHCAHPS Annual Payment Update (APU) data for years. That’s about to change — at least if CMS has its way.
In the Calendar Year 2027 Home Health Prospective Payment System (HH PPS) Notice of Proposed Rulemaking (NPRM), published July 6, 2026, CMS is proposing to move the HH QRP OASIS and HHCAHPS APU reporting timeframe from the current July 1–June 30 cycle to a true calendar year: January 1 through December 31.

Why This Matters
For agencies tracking quality reporting compliance, the reporting period isn’t just an administrative detail — it determines which assessments and survey data count toward the APU determination for a given payment year, and it shapes internal deadlines for data submission and correction. A shift in the underlying timeframe touches OASIS workflows, HHCAHPS vendor coordination, and the broader compliance calendar HHAs build their year around.

CMS has framed this change as part of a larger effort to align the HH QRP more closely with the expanded Home Health Value-Based Purchasing (HHVBP) Model, which already operates on a calendar-year basis. Bringing APU reporting onto the same calendar-year footing simplifies the overall reporting picture for agencies juggling both programs.

What’s Changing: From July–June to January–December
Right now, the APU reporting period runs from July 1 through June 30. Under the proposal, both OASIS and HHCAHPS APU data would instead be reported on a January 1–December 31 calendar-year basis. That’s a clean, intuitive change on paper — but getting there requires a transition period, since CMS can’t simply erase six months of data or double-count a stretch of time.

The Transition: How CMS Gets From Here to There
Rather than an abrupt cutover, CMS has proposed a phased transition using shortened, “bridge” reporting periods:

2028 APU determination

• OASIS data: six months, covering July 1, 2026 through December 31, 2026
• HHCAHPS data: nine months, covering April 1, 2026 through December 31, 2026

2029 APU determination

• The first full calendar-year cycle for both OASIS and HHCAHPS, covering January 1, 2027 through December 31, 2027

In other words, the 2028 APU year acts as a bridge — a shortened data collection window that nudges both programs onto the calendar-year track — and by 2029, everything is running January through December going forward.

What Agencies Should Do Now
This is a proposed rule, not a final one. The comment period runs through August 31, 2026, and CMS could adjust the details before finalizing anything. Still, agencies that get ahead of this now will be better positioned regardless of what changes between the proposed and final rule:

• Review internal OASIS and HHCAHPS reporting calendars against the proposed bridge periods
• Flag the shortened 2028 APU windows for staff who track compliance thresholds, since a six- or nine-month window behaves differently than a full year
• Watch for the final rule, expected later in 2026, to confirm whether these timeframes hold

The Bottom Line
CMS wants to simplify home health quality reporting by putting OASIS and HHCAHPS APU data on the same calendar-year clock as the expanded HHVBP Model. Getting there means a transitional 2028 APU year built on shortened data windows, with the first full calendar-year cycle landing in 2029. It’s a modest structural change, but one that will ripple into how agencies plan their reporting and compliance calendars for the next several years.

This post is based on the CY 2027 Home Health PPS Notice of Proposed Rulemaking (CMS-1844-P), published in the Federal Register on July 6, 2026. The comment period closes August 31, 2026.

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