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 Jan. 1, 2025, and Dec. 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.
