The Occupational Mix Survey (OMS) is more than a regulatory requirement; it’s a powerful tool that shapes your hospital’s Medicare payments for years to come.

Often, the work to gather payroll data and map hundreds of job codes to complete the OMS starts just before the June submission deadline. This can compress the process and increase the likelihood of mistakes.

Hospitals that plan early and approach the survey strategically can position themselves to help optimize reimbursement, reduce audit risks, and strengthen workforce management.

Why Planning for the OMS Matters

The OMS collects detailed data on your hospital’s nursing and overall workforce. CMS uses this data to adjust the wage index, which is a key factor in determining Medicare payments. Because of the unique nature of the data, and its importance to reimbursement, planning is essential for coordinating the completion of the OMS.

Five Reasons to Plan Early for the Occupational Mix Survey

1. Data collection is complex. Gathering accurate payroll and staffing data involves multiple departments including human resources, payroll, nursing administration, and IT. Without a coordinated data request, it’s possible to miss something that can delay the data gathering process.
2. Job code mapping is challenging. The OMS requires job codes that align with the Bureau of Labor Statistics (BLS) categories. However, many hospitals have job codes that do not necessarily match the BLS one-for-one. This means hospitals will have to map their job codes to the BLS codes, which can be time intensive, requiring careful review and cross-checking to ensure accuracy.
3. IT and security can extend lead time. Recent cybersecurity concerns have led hospitals to increase their security procedures. This is excellent. However, it has an unintended side effect: requesting data can require additional lead time.
4. Contract labor must be included. Contracted staff hours need to be tracked and reported separately in the OMS, adding another layer of complexity and another data item to report. Connecting with vendors to get the necessary information can also be a time-consuming process.
5. Errors can be avoided. Without comprehensive planning, the likelihood of misclassifying staff or missing data increases, which can lead to inaccurate reports and potential payment reductions.

Proper planning ensures enough time and resources to collect, verify, and submit accurate data. Starting early allows teams to work through the process methodically and reduces opportunities for mistakes that can lead to unexpected outcomes. That’s why planning is essential to completing the OMS accurately and strategically.

Seven Key Actions to Guide Your Planning Process

1. Review past OMS data. Analyze previous survey submissions and audit adjustments to identify areas needing improvement.
2. Engage key stakeholders. Set up initial meetings with HR, payroll, nursing administration, and IT to coordinate data collection and clarify reporting deadlines. This also creates an opportunity to align across departments and demonstrate collaboration as you complete the survey and help with the hospital’s reimbursement.
3. Gather payroll and staffing data. Request detailed employee hours, job titles, and contract labor information for the entire calendar year.
4. Map job codes to BLS categories. Work with HR, and possibly nursing administration, to align internal job codes with the official occupational categories used by CMS. This process can take time depending on how the job codes are mapped.
5. Validate and reconcile data. Cross-check payroll reports against financial records to ensure completeness and accuracy prior to submission.
6. Plan for contingencies. Account for potential delays due to IT security or staffing changes by building in buffer time.
7. Consider expert support. Engage consultants, like our advisors, early to review data and processes, ensuring compliance and accuracy.

Occupational Mix Survey Planning Timeline

• February to March. Review past survey data and payroll records, and engage key teams like HR, payroll, nursing, and finance to plan the work. If time limitations prevent a thorough review of the codes and processes, then engage with a third party early to ensure accurate reporting.
• March to April. Collect current payroll and staffing data and begin mapping job codes to the required occupational categories.
• April to May. Prepare a draft of the survey data, perform initial quality checks, and consider consulting experts for accuracy.
• May to mid-June. Conduct final reviews and audits of the data, make necessary adjustments, and submit the completed survey on time with all required documentation.

The Risks of Waiting

The benefits of planning are clear and simple: a more thorough approach can lead to more accurate data on the OMS, which can result in a more accurate reimbursement. However, potential missteps can occur by viewing the OMS as another government form that can be competed quickly. And while a thorough approach can lead to better results, a rushed approach can lead to more risk.

Five Risks of Not Planning Your OMS Submission

1. Reduced Medicare payments. Not submitting the OMS, or submitting it with inaccurate data, can cause CMS to apply geographic factors. This means instead of receiving payments based on a hospital’s actual staffing costs, Medicare may use a generic or lower adjustment factor. The result? Hospitals could face significant reductions in Medicare reimbursement, potentially costing millions of dollars over the three years the adjustment applies. This loss directly impacts hospital budgets, limiting resources available for patient care and operations.

2. Increased risk of audit. Errors, inconsistencies, or incomplete data in the survey responses can raise red flags for CMS and auditors. An audit triggered by survey inaccuracies can be time-consuming, stressful, and expensive.

3. Operational disruption. Waiting until the last minute to gather data puts enormous pressure on HR, payroll, and IT departments. These teams may be forced to scramble to pull complex reports, verify job codes, and reconcile data under tight deadlines. This rush can disrupt regular work, delay other important projects, and increase the likelihood of mistakes. Early planning spreads the workload, reduces stress, and ensures smoother collaboration across departments.

4. Misclassification of staff. The OMS requires precise classification of nursing roles according to Bureau of Labor Statistics categories. Without careful review, hospitals often overstate categories like Registered Nurses or underreport aids and assistants. Such misclassification can skew occupational mix adjustment negatively, leading to understated wage index factors. This can ultimately reduce Medicare payments. Taking time to validate job roles and payroll codes are essential steps to avoid costly errors.

5. Lost strategic insight. Beyond compliance, the OMS offers valuable insights into workforce composition and utilization. Rushing the survey means missing the chance to analyze staffing patterns, identify inefficiencies, and optimize resource allocation. Hospitals able to plan ahead can use the survey data to inform workforce strategies, improve patient care, and strengthen financial performance, which can provide a strategic advantage in a competitive and evolving healthcare environment.

We’re Here to Help

For help navigating the complexities of the OMS process or a no-obligation review of your prior OMS by a team that specializes in regulations and reporting, contact your firm professional.

Additional Resources

• Health Care Practice
• Health Care Consulting Services