The short answer, for the assessment that takes longest:
All six OASIS-E time points
OASIS is completed at more than one moment in an episode of care, and the instrument is much shorter at some of them than at others. The full set of CMS estimates:
| OASIS-E time point | Estimated clinician minutes |
|---|---|
| Start of Care | 57.3 |
| Resumption of Care | 48.0 |
| Discharge | 40.2 |
| Follow-Up | 11.1 |
| Transfer of Care | 6.6 |
| Death at Home | 2.7 |
Estimates are per assessment, for the clinician completing it.
Where these numbers come from
They are not the product of an independent time-and-motion study. They are the estimates CMS itself published in the Collection of Information Requirements section of the CY 2023 Home Health Prospective Payment System final rule, prepared to satisfy the Paperwork Reduction Act — the statute that requires a federal agency to account for the reporting burden any information collection places on the public.
That provenance matters in both directions. It means the figure carries federal authority and can be cited without qualification as CMS’s own position. It also means it is an agency estimate produced for regulatory accounting, not an observation of clinicians at work in the field.
Which version of OASIS these figures describe
This matters, because the instrument has changed since the estimates were published. The 57.3-minute figure describes OASIS-E, as assessed in the CY 2023 rule. OASIS-E1 took effect January 1, 2025, and the CY 2026 Home Health Prospective Payment System final rule removes four standardized patient assessment items beginning in CY 2026 — one Living Situation item, two Food items, and one Utilities item.
CMS has not published a revised per-assessment burden estimate alongside those changes. The CY 2023 figures remain the most recent estimates of this kind, which is why they are the ones in circulation. Anyone citing them should say which instrument version they describe. The direction of the change is worth noting too: removing items should reduce completion time, not increase it, so 57.3 minutes is more likely to overstate the current Start of Care burden than to understate it.
The annual total
Aggregated across all Medicare-certified home health agencies, CMS puts the annual burden of OASIS assessments at roughly 14.6 million clinician hours and $1.17 billion in clinician time.
What the estimate does not include. It covers the OASIS instrument and nothing else. Visit notes, plans of care, medication reconciliation outside the OASIS items, communication with physicians, and care coordination all fall outside it.
The total documentation load in home-based care is therefore larger than $1.17 billion by an unknown margin — unknown because no published United States study has measured it. That gap, and the European studies that partially address it, are covered in the companion note on documentation burden.
Does OASIS make assessments longer than they would otherwise be?
This is frequently asserted and rarely sourced. The one study that examined it directly, in Home Health Care Services Quarterly, reported that the time to complete an assessment with OASIS did not differ from the time to complete a comparable assessment without it. The study is old enough that it should not be treated as current evidence about OASIS-E specifically. It is cited here for a narrow purpose: the claim that OASIS substantially lengthened assessment time has no published support, and should not be repeated as though it did.
Why the figure gets used
Because it is the only federal number of its kind, the 57.3-minute estimate carries more weight in policy argument than a single agency estimate normally would. It is worth stating precisely what it supports: that CMS acknowledges a substantial documentation burden attached to one instrument, at a scale of roughly 14.6 million clinician hours a year. It does not support any claim about the total burden, and it does not establish what any particular intervention would reduce.
Common questions
How long does an OASIS-E Start of Care assessment take?
CMS estimates 57.3 minutes of clinician time for a single OASIS-E Start of Care assessment.
How long do the other OASIS-E time points take?
CMS estimates 48.0 minutes for Resumption of Care, 40.2 minutes for Discharge, 11.1 minutes for Follow-Up, 6.6 minutes for Transfer of Care, and 2.7 minutes for Death at Home.
Where does the 57.3 minute figure come from?
The Paperwork Reduction Act burden estimates that CMS published with the CY 2023 Home Health Prospective Payment System final rule. It is CMS's own estimate, not an independent measurement.
What is the total annual OASIS burden across all agencies?
CMS puts it at roughly 14.6 million clinician hours and $1.17 billion in clinician time each year, across all Medicare-certified home health agencies.
Does the estimate include visit notes and care plans?
No. The estimate covers the OASIS instrument only. Visit documentation, plans of care, and care coordination fall outside it and have never been measured nationally in the United States.
Do these figures apply to OASIS-E1?
They describe OASIS-E, as assessed in the CY 2023 rule. OASIS-E1 took effect January 1, 2025, and the CY 2026 final rule removes four standardized patient assessment items. CMS has not published a revised per-assessment burden estimate, so the CY 2023 figures remain the most recent of their kind. Because items were removed rather than added, 57.3 minutes is more likely to overstate current Start of Care burden than to understate it.
Sources
- Centers for Medicare & Medicaid Services, Medicare Program; Calendar Year 2023 Home Health Prospective Payment System Rate Update, Collection of Information Requirements. Federal Register 2022-23722.
- Centers for Medicare & Medicaid Services, OASIS-E1 All Items, effective January 1, 2025. CMS (PDF).
- Centers for Medicare & Medicaid Services, Calendar Year (CY) 2026 Home Health Prospective Payment System Final Rule (CMS-1828-F) fact sheet, for the four standardized patient assessment items removed beginning CY 2026. CMS.
- Study of OASIS and assessment time, Home Health Care Services Quarterly. PubMed 29016255. Cited only to show that the opposite claim is unsupported.
- Medicare Payment Advisory Commission, Report to the Congress: Medicare Payment Policy, Chapter 8, Home Health Care Services, March 2026. MedPAC.
Related
Documentation in home-based care: what is measured, and what isn’tWhat the OASIS estimate leaves out, and why no US study has filled the gap. The direct care workforce, in numbersWho absorbs the documentation load, at what wage, and at what turnover rate.Published July 31, 2026. Corrections to rupakshah@pyramid.care.