A Complete Guide to the Occupational Mix Survey
Medicare reimbursement is a complex landscape shaped by numerous factors, but few are as impactful—and as underappreciated—as the Occupational Mix Survey (OMS). It plays a vital role in ensuring your hospital receives fair and accurate Medicare payments.
Every three years, CMS requires hospitals to complete this survey which directly influences wage index adjustments that affect payments for years to come.
For hospitals paid under the Inpatient Prospective Payment System (IPPS), thoroughly understanding OMS requirements and approaching it with careful preparation safeguards financial stability.
- What’s the Occupational Mix Survey?
- Why Is the Occupational Mix Survey Important?
- How’s the Occupational Mix Survey Structured and What’s Required?
- Who’s Required to Complete the Occupational Mix Survey?
- When Is the Occupational Mix Survey Due?
- How Long Does the Occupational Mix Survey Take to Complete?
- What Are the Value and Impact of Completing the Occupational Mix Survey?
- Where Are the Instructions for Completing the Occupational Mix Survey?
- What Are Common Challenges and Errors Hospitals Experience When Completing the Occupational Mix Survey?
- What Are Best Practices for Completing the Occupational Mix Survey?
What’s the Occupational Mix Survey?
The OMS is a critical data collection tool used by CMS to adjust hospital wage-related payments under the Medicare program. Specifically, it’s designed to measure the mix of health care professionals employed by the hospital. These professionals include:
- Registered Nurses (RN)
- Licensed Practical Nurses (LPN)
- Licensed Vocational Nurses (LVN
- Surgical Technicians
- Nursing Assistants and Orderlies
- Medical Assistants
The OMS focuses on employee utilization based on their occupational category. Specifically, the OMS calculates an adjusted average hourly wage for the nursing categories listed above. The OMS also features an analysis of any contracted labor. CMS utilizes the data from this survey to adjust hospital payments. This process helps CMS account for the differences in wages that result from hospitals’ staffing decisions.
Unlike the annual wage data hospitals report on their Medicare Cost Reports, the OMS is mandated every three years and provides a more detailed snapshot of staff utilization. When aggregated with other hospitals across the nation, it allows CMS to adjust hospital payments by comparing the hospital’s staff utilization to the national averages.
Why Is the Occupational Mix Survey Important?
The OMS is important because it influences payment adjustments for hospitals within the prospective payment system. Specifically, the survey is used to identify the Occupational Mix Adjustment factor. This factor modifies a hospital’s wage index factor which influences their Medicare payments. Because of this, the OMS can directly impact Medicare payments for up to three years after the survey. That’s why accurate and timely completion of the survey is so important. An accurate survey helps hospitals receive appropriate reimbursement that reflects their true labor costs. Failing to submit the survey, or submitting it with errors, can result in wage-related payments that are not representative of your hospital’s staffing utilization, which could potentially reduce reimbursement.
How’s the Occupational Mix Survey Structured and What’s Required?
The OMS is structured around Standard Occupational Categories (SOCs) defined by the U.S. Bureau of Labor Statistics. The form is relatively straightforward, looking like this:
To complete the survey, hospitals must carefully map their internal job codes to these SOCs, ensuring all relevant staff are included and properly categorized. From there, total paid hours need to be adjusted for excluded hours and reported for each category.Examples of hours that are included in the survey are regular hours, overtime, paid holidays, vacation, sick leave, paid time off, and severance pay. Overall, the survey reports:
- Full-time and part-time staff, including contracted workers. However, it excludes any employees working in components not covered by the IPPS.
- Total hours worked by each occupational category during the calendar year. Contracted labor hours should be included in their respective staffing categories.
- Contract labor should not include non-wage expenses like travel or lodging.
When it’s completed, the OMS reports all the total paid hours for the four nursing categories, as well as all other employee types that are required to be reported.
Who’s Required to Complete the Occupational Mix Survey?
Hospitals paid under the IPPS must complete the OMS. Exemptions include:
- Critical Access Hospitals (CAHs)
- Psychiatric hospitals
- Rehabilitation hospitals
- Long-Term Care hospitals
- Children’s hospitals
- Veterans hospitals
- Hospitals with low or no Medicare utilization
- Hospitals that terminated Medicare participation before the survey period
When Is the Occupational Mix Survey Due?
The 2025 Occupational Mix Survey is due to your Medicare Administrative Contractor (MAC) by June 30, 2026.
The survey covers the 12-month period, from pay periods ending between January 1, 2025, and December 31, 2025. The results of the survey will be applied to the FY 2028 - FY2030 wage index.
How Long Does Occupational Mix Survey Take to Complete?
CMS estimates the OMS could require up to 480 hours to complete, including data gathering, job code mapping, and internal review. In theory, if hospitals have job codes that align with the BLS job codes, and the process for gathering payroll and job data is simplified, then this can be a manageable process. However, for many hospitals, these processes can take time. This is especially true in today’s environment of increased IT security and reporting protocols.
The time it takes to complete the OMS varies based on every hospital’s team, needs, and situation. Therefore, the key is to assess your data and processes, and make sure you have plenty of time to follow the survey instructions.
Sample Timeline
- Start today. Review past survey data and payroll records, and engage key teams like HR, payroll, nursing, and finance to plan the work.
- Three to four months before deadline. Collect current payroll and staffing data and begin mapping job codes to the required occupational categories.
- Two to three months before deadline. Prepare a draft of the survey data, perform initial quality checks, and consider consulting experts for accuracy.
- One month before deadline. Conduct final reviews and audits of the data, make necessary adjustments, and submit the completed survey on time with all required documentation.
What Are the Value and Impact of Completing the Occupational Mix Survey?
Because the OMS directly influences Medicare payments, completing the survey accurately ensures your hospital receives appropriate reimbursement payments. Hospitals with a higher mix of lower-paid nursing staff may receive increased payments, while those with more highly skilled and compensated nurses might see reductions. Therefore, the key impact of completing the Occupational Mix Survey is confidence in knowing that your payments are accurately adjusted based on the needs of your hospital.
Where Are the Instructions for Completing the Occupational Mix Survey?
The Occupational Mix Survey is officially titled Form CMS-10079. Review the form and download the instructions.
What Are Common Challenges and Errors Hospitals Experience When Completing the Occupational Mix Survey?
The most common challenge is time. The OMS can be very time-consuming. Often, it can be difficult to obtain the necessary data and compile it accurately, and sometimes, hospitals find that they start the process too late or don’t allocate enough resources to complete the survey. That’s why the best way to address these challenges is to have a plan that’s customized to your hospital’s needs.
In addition to time, potential challenges include:
- Difficulty obtaining payroll and contract labor with the necessary data points
- Misclassifying nursing staff or administrative roles
- Omitting contract labor hours
- Including staff reported in cost centers excluded from wage index in the survey
- Changes in payroll and general ledger systems
- Not accounting for reclassifications completed on the Medicare Cost Report
What Are Best Practices for Completing the Occupational Mix Survey?
The best practice a hospital can use is starting the process early. With proper planning and coordination, a hospital can successfully navigate the Occupational Mix Survey submission. In addition to planning, here are a few approaches that can assist hospitals:
Engage Key Stakeholders Early
Coordinate and communicate with human resources, payroll, nursing leadership, and IT teams from the beginning. Clearly identify the information needed, explain that it’s required for federal reporting, and emphasize that accurate data impacts federal funding.
Assess and Update Job Titles and Descriptions
Work with HR and payroll leaders to review the full list of employee job titles and descriptions, focusing on primary and secondary duties within the Bureau of Labor Statistics’ SOCs and occupational mix categories required for the survey. Produce a preliminary list of any new positions that have been added since the prior reporting period.
Align Payroll Codes with SOCs
Update job descriptions and payroll codes to match the BLS SOC codes as closely as possible. If exact matches aren’t feasible, develop a cross-reference document that clearly maps your hospital’s internal codes to the appropriate SOCs to streamline reporting and review.
Review Earnings Codes and Payroll Data
Examine all earning codes and definitions within your payroll system, including shift differentials, overtime, holiday pay, and paid time off. Review current-year payroll files and compare them to those from three years ago, keeping in mind that the last survey period included the Public Health Emergency, which affected staffing and payroll differently.
Identify Eligible Staff and Exclude Non-Eligible Employees
Ensure that all eligible staff—full-time, part-time, employees, and contracted workers—are included in the survey. Pay close attention to the survey’s definitions and instructions to exclude any non-eligible personnel accurately.
Compile Contract Labor Information
Gather and organize documentation for all contract labor agreements relevant to the occupational mix categories, such as RNs, LPNs, CNAs, aides, and orderlies. Prepare schedules from both the prior report and the current period to ensure completeness.
Calculate Average Hourly Wage Tests
Produce or compute an average hourly wage test for the current period. This can help identify which payroll data is allowable and which should be excluded from the survey.
Account for Home Office and Related Organization Employees
Prepare an updated list of employees from your health system’s home office or related organizations who provide services to the hospital and may be allocated through Home Office Cost Reporting guidelines.
Review Prior Surveys and Audit Adjustments
Analyze previous OMS submissions and any audit adjustments to identify trends or necessary changes that can improve accuracy in the current reporting cycle.
Maintain Thorough Documentation
Throughout the process, keep organized and accessible records of all resources, data sources, and decisions made. This documentation will be invaluable for internal reviews and potential audits.
What Else Should Hospitals Know About the Occupational Mix Survey?
The OMS has a direct impact on your hospital’s Medicare payments for up to three years. That’s why accurately reporting OMS data is an essential step to ensure accurate payments. Even small errors or misclassifications can lead to significant financial consequences, either reducing your reimbursement.
Beyond meeting regulatory requirements, the OMS provides a meaningful opportunity to better understand your workforce composition and staffing trends relative to peer organizations and your service area. Thoughtful analysis and accurate reporting of this data can help your hospital pinpoint opportunities to review staffing, improve resource deployment, and more effectively align workforce strategies with patient care needs.
We’re Here to Help
For help navigating the complexities of the OMS or a no-obligation review of your prior OMS by a team that specializes in regulations and reporting, contact your firm professional.