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  • Writer's pictureAmara Kamara

FAQ On Home Health Agency Medicare Site Surveys: Process & Survival Guide

Updated: Oct 14, 2023

Navigating the complexities of a Home Health Agency (HHA) Medicare site survey can seem daunting for many providers. This comprehensive FAQ based on Waiver Consulting Group's 20 years of experience is designed to shed light on the ins and outs of the HHA site survey, from understanding the very purpose of these evaluations to preparing your agency for a successful assessment.


FAQ On Home Health Agency Medicare Site Surveys: Process & Survival Guide

Consider this your survival guide, providing you with vital information, best practices, and expert tips to ensure not only compliance but also excellence. Dive in to get clarity on common questions, discover how to avoid common pitfalls, and gain confidence in the survey process. Whether you're a seasoned provider or a newcomer to the industry, this guide is an indispensable resource to help you navigate the HHA site survey with ease.


When in doubt or in need of professional support for a successful survey, don't hesitate to contact us at the Waiver Consulting Group. Reach us at 302-888-9172 or drop us an email at licensing@waivergroup.com.


Medicare Site Surveys: Process & Survival Guide


FREQUENTLY ASKED QUESTIONS


My home health care agency survey coming up. Do you have a survival guide you could share?

Yes, here's an abridge list of guides for home health site surveys:

  1. Create and maintain a survey readiness binder for the office

  2. Identify key leaders to guide the organization and home health staff

  3. Ensure that the entire staff has a strong understanding of the current home health conditions of participation (CoPs)

  4. Incorporate CoP education into an orientation program for new staff members and provide rolling updates for current staff

  5. Review previous surveys, complaints or other investigations, CASPER reports, Home Health comparisons, and what comprises the agency's Quality Assessment and Performance Improvement (QAPI) program

  6. Be prepared to provide documentation at the site of a survey within eight working hours of the request to demonstrate compliance

  7. Prove that your organization meets the expected standard of care, safety, and other compliance and regulatory requirements

It's important to note that there are different kinds of surveys that are relevant to home health providers, including state surveys, the deemed status accreditation survey, and the Centers for Medicare & Medicaid Services (CMS) validation survey. Providers should be prepared for unexpected interpretations and requirements during the survey process.


What are the key steps to prepare for a home health survey?

To prepare for a home health survey, here are some key steps to follow:

  1. Create and maintain a survey readiness binder for the office and online

  2. Identify key leaders to guide the organization and home health staff

  3. Ensure that the entire staff has a strong understanding of the current home health conditions of participation (CoPs)

  4. Incorporate CoP education into an orientation program for new staff members and provide rolling updates for current staff

  5. Review previous surveys, complaints or other investigations, CASPER reports, Home Health comparisons, and what comprises the agency's Quality Assessment and Performance Improvement (QAPI) program

  6. Understand the Medicare Conditions of Participation (CoPs) and the interpretive guidelines

  7. Implement ACHC Accreditation Standards

  8. Audit personnel files and medical records to help identify areas for improvement prior to the survey

  9. Educate staff to ensure they understand the importance of written instructions that are patient-and task-specific, and avoid any ambiguity regarding the tasks the aide is to perform

It's important to note that there are different kinds of surveys that are relevant to home health providers, including state surveys, the deemed status accreditation survey, and the Centers for Medicare & Medicaid Services (CMS) validation survey. Providers should be prepared for unexpected interpretations and requirements during the survey process


Medicare Certification Survey

What is a survey readiness binder and how can I create one for my home health agency?

A survey readiness binder is a collection of documents and information that home health providers can use to prepare for a survey. It is a tool that can help providers ensure that they are in compliance with regulations and standards, and that they are ready to demonstrate their compliance to surveyors. Here are some steps to create a survey readiness binder for your home health agency:

  1. Gather information from your accrediting body or state about the different things they want for the survey

  2. Include the current home health conditions of participation (CoPs) and interpretive guidelines

  3. Incorporate CoP education into an orientation program for new staff members and provide rolling updates for current staff

  4. Review previous surveys, complaints or other investigations, CASPER reports, Home Health comparisons, and what comprises the agency's Quality Assessment and Performance Improvement (QAPI) program

  5. Audit personnel files and medical records to help identify areas for improvement prior to the survey

  6. Include emergency preparedness plan that must be reviewed, and updated at least annually

  7. Have the updated floor plan, Hospice Agreements, Dialysis Agreements, ANE policy and other items that can be readily available in the binder in the case the survey team shows up

  8. Assemble a Survey Readiness 3 Ring Binder that includes all the basic information surveyors will request upon arrival at the Assisted Living Home Care

By creating and maintaining a survey readiness binder, home health providers can be better prepared for the survey process and demonstrate their knowledge and compliance to surveyors.


What are the essential components of a survey readiness binder for a home health agency?

Based on the our 20 years of experience, we advice our clients to these essential components of a survey readiness binder for their home health agency:

  1. A copy of current applicable licenses or permits

  2. A current 855A/CMS approval letter

  3. The current home health conditions of participation (CoPs) and interpretive guidelines

  4. CoP education materials for staff

  5. Previous surveys, complaints or other investigations, CASPER reports, Home Health comparisons, and what comprises the agency's Quality Assessment and Performance Improvement (QAPI) program

  6. Emergency preparedness plan that must be reviewed and updated at least annually

  7. Updated floor plan, Hospice Agreements, Dialysis Agreements, ANE policy, and other items that can be readily available in the binder in case the survey team shows up

  8. Documentation for a survey readiness Entrance Conference

By including these components in a survey readiness binder, home health providers can be better prepared for the survey process and demonstrate their knowledge and compliance to surveyors.


Medicare Onsite Survey

How can I ensure that my agency's 855A/CMS approval letter is up to date and included in the survey readiness binder?

To ensure that your agency's 855A/CMS approval letter is up to date and included in the survey readiness binder, you can follow these steps:

  1. Check the expiration date of your current 855A/CMS approval letter

  2. Submit a new 855A application to CMS if your current approval letter is expired or about to expire

  3. Include a copy of the current 855A/CMS approval letter in your survey readiness binder

It's important to keep your 855A/CMS approval letter up to date because it is required for participation in the Medicare program. By including it in your survey readiness binder, you can demonstrate your compliance with this requirement to surveyors.


What is the process for updating the 855A/CMS approval letter for a home health agency?

To update the 855A/CMS approval letter for a home health agency, you can follow these steps:

  1. Check the expiration date of your current 855A/CMS approval letter

  2. Submit a new 855A application to CMS if your current approval letter is expired or about to expire

  3. Include a copy of the current 855A/CMS approval letter in your survey readiness binder

To submit a new 855A application, you can follow these steps:

  1. Download the CMS-855A form from the CMS website

  2. Complete the form with all required information

  3. Submit the completed form and all supporting documentation to your fee-for-service contractor

It's important to keep your 855A/CMS approval letter up to date because it is required for participation in the Medicare program. By including it in your survey readiness binder, you can demonstrate your compliance with this requirement to surveyors.


What is the difference between the CMS-855A and CMS-855S enrollment applications?

The CMS-855A and CMS-855S are both enrollment applications for Medicare providers, but they are used for different types of providers. Here are the differences between the two:


CMS-855A:

  • Used by institutional providers, such as hospitals, skilled nursing facilities, and home health agencies

  • Required for participation in the Medicare program

  • Must be submitted to CMS to enroll in Medicare or to make changes to enrollment information

CMS-855S:

  • Used by Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers

  • Required for participation in the Medicare program

  • Must be submitted to the National Supplier Clearinghouse (NSC) to enroll in Medicare or to make changes to enrollment information

It's important to use the correct enrollment application for your provider type to ensure that you are in compliance with Medicare regulations.


Waiver Consulting Group Site Survey Guide

What types of providers are required to submit a CMS-855A enrollment application?

Institutional providers are required to submit a CMS-855A enrollment application. Institutional providers are defined as organizations that provide health care or services to patients in a non-private residence and are enrolled in the Medicare program. Examples of institutional providers include hospitals, skilled nursing facilities, and home health agencies. The CMS-855A is used to enroll in Medicare or to make changes to enrollment information. The application must be submitted to the Medicare Administrative Contractor (MAC) serving the state where the provider is located. The MAC screens and validates the application, and submits a recommendation of approval to the state agency. The state agency conducts an on-site certification survey, and if the conditions of participation are met, the CMS Regional Office issues a provider agreement and assigns a provider number. The CMS-855A must be completed within 30 days of a change in ownership, an adverse legal action, or a change in practice location, and within 90 days for managing employees, AO/DO, and all other changes. Providers must use electronic funds transfer (EFT) if enrolling in Medicare, revalidating, or making changes to their enrollment.


What is the difference between institutional and non-institutional providers in the context of the CMS-855A enrollment application?

In the context of the CMS-855A enrollment application, institutional providers are defined as organizations that provide health care or services to patients in a non-private residence and are enrolled in the Medicare program. Examples of institutional providers include hospitals, skilled nursing facilities, and home health agencies. Institutional providers are required to submit a CMS-855A enrollment application to enroll in Medicare or to make changes to enrollment information. On the other hand, non-institutional providers are not required to submit a CMS-855A enrollment application. Non-institutional providers include physicians, non-physician practitioners, clinics, group practices, and certain other suppliers. Non-institutional providers use different enrollment applications, such as the CMS-855I for physicians and non-physician practitioners, the CMS-855B for clinics, group practices, and certain other suppliers, and the CMS-855S for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers.


Are there any differences in the enrollment process between institutional and non-institutional providers for the CMS-855A enrollment application?

The enrollment process for the CMS-855A enrollment application is different for institutional and non-institutional providers. Here are the differences: Institutional Providers:

  • Submit the CMS-855A enrollment application to the Medicare Administrative Contractor (MAC) serving the state where the provider is located

  • The MAC screens and validates the application, and submits a recommendation of approval to the state agency

  • The state agency conducts an on-site certification survey, and if the conditions of participation are met, the CMS Regional Office issues a provider agreement and assigns a provider number

  • The CMS-855A must be completed within 30 days of a change in ownership, an adverse legal action, or a change in practice location, and within 90 days for managing employees, AO/DO, and all other changes

  • Providers must use electronic funds transfer (EFT) if enrolling in Medicare, revalidating, or making changes to their enrollment

Non-Institutional Providers:

  • Submit different enrollment applications depending on their provider type, such as the CMS-855I for physicians and non-physician practitioners, the CMS-855B for clinics, group practices, and certain other suppliers, and the CMS-855S for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers

  • Submit the enrollment application to the National Supplier Clearinghouse (NSC) for DMEPOS suppliers, and to the MAC for other non-institutional providers

  • Providers must use electronic funds transfer (EFT) if enrolling in Medicare, revalidating, or making changes to their enrollment

It's important to use the correct enrollment application and follow the correct enrollment process for your provider type to ensure that you are in compliance with Medicare regulations.


Quality Assessment Site Survey for HHA

Are surveys announced or unannounced?

Surveys for home health agencies (HHAs) must be unannounced, whether Routine (initial or 36-month resurvey), Complaint, Change of Ownership (CHOW), Reactivation of Billing, Significant Change in Services, Addition of a Branch, Look-Behind, or Validation. This means that HHAs must always be prepared for a surveyor visit since surveys may occur at any time, not just within the 36-month resurvey timeline The unannounced survey process is designed to ensure that surveyors can observe the agency's day-to-day operations and assess compliance with regulations and standards. All HHA surveys must be unannounced and conducted with procedures and scheduling that renders the onsite surveys as unpredictable in their timing as possible It's important for HHAs to be prepared for surveys at all times to ensure that they are in compliance with regulations and standards and can demonstrate their compliance to surveyors.


How can I ensure that my agency is prepared for a surveyor visit?

Here are some tips on how a provider can ensure that they are prepared for a surveyor visit:

  1. Identify the survey process and general requirements

  2. Ensure that the entire staff has a strong understanding of the current home health conditions of participation (CoPs) and incorporate this education into an orientation program for new staff members

  3. Create and maintain a survey readiness binder for the office and online

  4. Have a list of staff members who will assist in the survey

  5. Ensure that all required documentation is readily available

  6. Organize a mock survey at least once a year to determine if the organization is CoP compliant and what areas call for further improvement

  7. Conduct regular spot-checks of the facility to identify and fix issues before the surveyors do

  8. Be prepared to provide documentation at the site of a survey within eight working hours of the request to demonstrate compliance

  9. Prove that your organization meets the expected standard of care, safety, and other compliance and regulatory requirements

By following these tips, providers can ensure that they are prepared for a surveyor visit and can demonstrate their compliance with regulations and standards.


What are some common areas that surveyors look for during a visit?

During a surveyor visit, there are several areas that surveyors may look for to assess compliance with regulations and standards. Here are some common areas that surveyors look for during a visit:

  1. Patient care and safety, including the quality of care provided by the agency

  2. Compliance with the current home health conditions of participation (CoPs) and interpretive guidelines

  3. Documentation and record-keeping, including the plan of care, medical record, and agency chart

  4. Staff qualifications and training, including home health aide qualifications and competency evaluations

  5. Emergency preparedness plan and procedures

  6. Infection control and prevention

  7. Patient rights and responsibilities

  8. Physical environment, including the patient's property, both inside and outside the home

  9. Electronic health records and software that conforms to the FIPS 140-2

By ensuring compliance with these areas, providers can be better prepared for a surveyor visit and demonstrate their knowledge and compliance to surveyors.


What are some common deficiencies found during home health agency surveys?

Based on our experience assisting provider agencies, here are some common deficiencies found during home health agency surveys:

  1. Plan of Care (POC) deficiencies, including failure to provide all ordered services, failure to incorporate all necessary information into the POC, and failure to have a written POC for each patient accepted to services

  2. Patient care and safety deficiencies, including failure to provide adequate care, failure to follow physician orders, and failure to ensure patient safety

  3. Staff qualifications and training deficiencies, including failure to ensure that staff members are qualified and competent to perform their duties

  4. Documentation and record-keeping deficiencies, including failure to maintain accurate and complete records, failure to document services provided, and failure to ensure that records are accessible and secure

  5. Emergency preparedness plan and procedures deficiencies, including failure to have an emergency preparedness plan, failure to conduct drills, and failure to ensure that staff members are trained on emergency procedures

  6. Infection control and prevention deficiencies, including failure to follow infection control procedures, failure to ensure that staff members are trained on infection control, and failure to maintain a clean and safe environment

  7. Patient rights and responsibilities deficiencies, including failure to inform patients of their rights and responsibilities, failure to obtain informed consent, and failure to ensure that patients are treated with dignity and respect

By addressing these common deficiencies, home health agencies can improve their compliance with regulations and standards and be better prepared for surveyor visits.


Home Health Agency Survey Guide

What are some examples of "plan of care" deficiencies found during home health agency surveys?

Based on our experience in the field, here are some examples of "plan of care" deficiencies found during home health agency surveys:

  1. Failure to provide all ordered services

  2. Failure to incorporate all necessary information into the POC

  3. Failure to have a written POC for each patient accepted to services

  4. Failure to ensure that the POC includes all required elements before submission to the physician for signature

  5. Failure to review medical records for compliance with following physician orders and obtaining orders to update the POC as necessary

  6. Failure to ensure documentation meets all requirements for complete interim orders and visit notes

By addressing these common deficiencies related to the plan of care, home health agencies can improve their compliance with regulations and standards and be better prepared for surveyor visits.


How can I ensure that home health agency is providing all ordered services?

To ensure that your home health agency is providing all ordered services, here are some tips:

  1. Ensure that the plan of care (POC) is complete and includes all necessary information before submission to the physician for signature

  2. Review medical records for compliance with following physician orders and obtaining orders to update the POC as necessary

  3. Ensure documentation meets all requirements for complete interim orders and visit notes

  4. Ensure that all services ordered through the POC and/or verbal orders are provided

  5. Monitor for under-utilization of services, which is when any service that is medically necessary is not provided

By following these tips, home health agencies can ensure that they are providing all ordered services and can demonstrate their compliance with regulations and standards to surveyors.


What is the "G" tag in home health site surveys?

The "G" tags assigned to each Condition of Participation (CoP) are used to identify the standards that are most related to patient care (Level 1), moderately related to patient care (Level 2), and least related to patient care (Level 3). Here are some examples of G tags related to the CoPs for home health agencies:

  1. G208: Condition of participation: Skilled professional services

  2. G434: Condition of participation: Patient rights

  3. G510: Condition of participation: Comprehensive assessment of patients

  4. G544: Condition of participation: Comprehensive assessment of patients

  5. G380: Condition of participation: Organization and administration of services

  6. G420: Condition of participation: Personnel qualifications

  7. G440: Condition of participation: Emergency preparedness

  8. G454: Condition of participation: Infection control

  9. G458: Condition of participation: Patient rights

  10. G464: Condition of participation: Comprehensive assessment of patients

By understanding the G tags related to the CoPs, home health agencies can better prepare for surveys and ensure compliance with regulations and standards.


How many types of surveys are conducted?

During a home health agency survey, there are two types of surveys that may be conducted: standard surveys and partial extended surveys. Here is what you need to know about each type of survey: Standard Survey:

  • A standard survey is a comprehensive review of the home health agency's compliance with regulations and standards

  • The survey includes a review of patient care, documentation, staff qualifications and training, emergency preparedness, infection control, and patient rights and responsibilities

  • Standard surveys are typically conducted every 36 months, but may be conducted more frequently if there are concerns about the agency's compliance

Partial Extended Survey:

  • A partial extended survey is conducted to determine if deficiencies and/or deficient practice(s) exist that were not fully examined during the standard survey or during a revisit

  • The survey is conducted when compliance with federal or accepted professional standards is not met for a specific condition of participation

  • Partial extended surveys may be conducted after substandard quality of care is found during an abbreviated standard survey or during a revisit

  • The survey may include a review of patient care, documentation, staff qualifications and training, emergency preparedness, infection control, and patient rights and responsibilities

By understanding the differences between standard surveys and partial extended surveys, home health agencies can be better prepared for surveys and ensure compliance with regulations and standards.


Survey Guide and Process for HHA Site Survey

When is a partial extended survey conducted?

A partial extended survey is conducted to determine if deficiencies and/or deficient practice(s) exist that were not fully examined during the standard survey. The survey may include a review of any additional requirements which would assist in making a compliance finding. Partial extended surveys may be conducted after substandard quality of care is found during an abbreviated standard survey or during a revisit The survey is conducted when compliance with federal or accepted professional standards is not met for a specific condition of participation. The survey may include a review of patient care, documentation, staff qualifications and training, emergency preparedness, infection control, and patient rights and responsibilities By conducting a partial extended survey, surveyors can ensure that all deficiencies and/or deficient practice(s) are identified and addressed, and that the home health agency is in compliance with regulations and standards.


What are some examples of conditions that may require a partial extended survey?

Here are some examples of conditions that may require a partial extended survey:

  1. A significant issue of non-compliance is found during an abbreviated standard survey or during a revisit

  2. Compliance with federal or accepted professional standards is not met for a specific condition of participation

  3. Substandard quality of care is found during an abbreviated standard survey or during a revisit

  4. Concerns that warrant added investigation in any of the areas reviewed during a standard survey

By conducting a partial extended survey, surveyors can ensure that all deficiencies and/or deficient practice(s) are identified and addressed, and that the home health agency is in compliance with regulations and standards.


What are some examples of conditions that may require an extended survey?

During a home health agency survey, an extended survey may be conducted when there are significant issues of non-compliance found during a standard survey or during a revisit. An extended survey is a more comprehensive review of the home health agency's compliance with regulations and standards than a standard survey. The survey may include a review of patient care, documentation, staff qualifications and training, emergency preparedness, infection control, and patient rights and responsibilities. An extended survey may also be conducted when compliance with federal or accepted professional standards is not met for a specific condition of participation. The survey may include a review of any additional requirements which would assist in making a compliance finding. By conducting an extended survey, surveyors can ensure that all deficiencies and/or deficient practice(s) are identified and addressed, and that the home health agency is in compliance with regulations and standards.


How are Deficiencies defined?

Deficiencies found during a home health agency survey are defined as either standard level or condition level deficiencies. Here is what you need to know about each level: Standard Level Deficiency:

  • A standard level deficiency is a deficiency that does not pose a serious threat to life safety

  • Standard level deficiencies are typically minor issues that can be corrected quickly and easily

  • Examples of standard level deficiencies include a missing fire drill record or a fire extinguisher missing several monthly checks

Condition Level Deficiency:

  • A condition level deficiency is a deficiency that poses a serious threat to life safety, but does not create an immediate jeopardy to life safety

  • Condition level deficiencies must be corrected within 60 days of the survey

  • If a condition level deficiency is not corrected within 60 days, the facility may be placed in immediate jeopardy

  • Examples of condition level deficiencies include a lack of correct fire sprinklers in a high-risk area or a failure to properly maintain fire alarm systems1.

By understanding the differences between standard level and condition level deficiencies, home health agencies can better prepare for surveys and ensure compliance with regulations and standards.


What are some examples of standard-level deficiencies in a home health agency?

Here are some examples of standard-level deficiencies in a home health agency:

  1. Plan of Care (POC) deficiencies, such as failure to provide all ordered services, failure to incorporate all necessary information into the POC, and failure to have a written POC for each patient accepted to services

  2. In-service training deficiencies, such as failure to provide in-service training to staff members on a regular basis

  3. Documentation and record-keeping deficiencies, such as failure to maintain accurate and complete records, failure to document services provided, and failure to ensure that records are accessible and secure

  4. Patient rights and responsibilities deficiencies, such as failure to inform patients of their rights and responsibilities, failure to obtain informed consent, and failure to ensure that patients are treated with dignity and respect

  5. Emergency preparedness plan and procedures deficiencies, such as failure to have an emergency preparedness plan, failure to conduct drills, and failure to ensure that staff members are trained on emergency procedures

  6. Infection control and prevention deficiencies, such as failure to follow infection control procedures, failure to ensure that staff members are trained on infection control, and failure to maintain a clean and safe environment

By addressing these common standard-level deficiencies, home health agencies can improve their compliance with regulations and standards and be better prepared for surveyor visits.


What are some examples of plan-of-care issues that can lead to standard-level deficiencies in a home health agency?

Here are some examples of plan-of-care issues that can lead to standard-level deficiencies in a home health agency:

  1. Failure to provide all ordered services

  2. Failure to incorporate all necessary information into the POC

  3. Failure to have a written POC for each patient accepted to services

  4. Failure to ensure that the POC includes all required elements before submission to the physician for signature

  5. Failure to review medical records for compliance with following physician orders and obtaining orders to update the POC as necessary

  6. Failure to ensure documentation meets all requirements for complete interim orders and visit notes

By addressing these common plan-of-care issues, home health agencies can improve their compliance with regulations and standards and be better prepared for surveyor visits.


Can you describe the HHA survey process?

The home health agency (HHA) survey process is patient-focused, outcome-oriented, and data-driven, making it more effective and efficient in assessing, monitoring, and evaluating the quality of care delivered by an HHA. The survey process incorporates an approach that is patient-centered, data-driven, and outcome-oriented, promoting high-quality patient care at all times through efficient and lower-cost care The CoPs focus on a patient-centered, data-driven, outcome-oriented model of care, with added standards regarding patient rights. The survey process includes a review of patient care, documentation, staff qualifications and training, emergency preparedness, infection control, and patient rights and responsibilities. The survey process is designed to ensure that surveyors can observe the agency's day-to-day operations and assess compliance with regulations and standards By following the survey process and focusing on patient-centered, data-driven, and outcome-oriented care, HHAs can improve their compliance with regulations and standards and be better prepared for surveyor visits.


What survey protocols and guidance surveyors use to prepare for the survey, conduct the survey, and evaluate the survey findings?

Surveyors use protocols and guidance to prepare for, conduct, and evaluate the findings of a home health agency (HHA) survey. Here are some examples of survey protocols and guidance used by surveyors:

  1. Home Health Agency (HHA) Survey Protocols: This document provides guidance to surveyors on how to conduct a survey of an HHA. The protocols cover topics such as patient rights, patient care, and emergency preparedness

  2. State Operations Manual Appendix B - Guidance to Surveyors: Home Health Agencies: This document provides guidance to surveyors on how to conduct a survey of an HHA. The guidance covers topics such as patient care, documentation, staff qualifications and training, emergency preparedness, infection control, and patient rights and responsibilities

  3. Protocols and Guidelines Manual - Home Health CAHPS: This manual provides guidance to home health agencies and survey vendors on how to participate in the Home Health Care CAHPS Survey. The manual covers topics such as survey participation requirements, sampling procedures, and public reporting

  4. Survey Program - Home Health Agencies: This program provides tools and checklists to guide surveyors through the survey process to determine an agency's compliance with the minimum standards of care. The program covers topics such as patient care, documentation, staff qualifications and training, emergency preparedness, infection control, and patient rights and responsibilities

By using these protocols and guidance, surveyors can ensure that they are conducting a thorough and effective survey of an HHA and evaluating the findings accurately.


Home Health Permits and Licensure Survey

What are the key components of the HHA survey protocol?

The Home Health Agency (HHA) Survey Protocol is a document that provides guidance to surveyors on how to conduct a survey of an HHA. The protocol covers the following key components:

  1. Patient Rights: This component includes a review of the HHA's policies and procedures related to patient rights, such as informed consent, advance directives, and confidentiality

  2. Patient Care: This component includes a review of the HHA's patient care practices, such as the assessment of patient needs, the development of a plan of care, and the provision of skilled services

  3. Emergency Preparedness: This component includes a review of the HHA's emergency preparedness plan and procedures, such as the identification of potential emergencies, the development of an emergency plan, and the training of staff members

  4. Infection Control: This component includes a review of the HHA's infection control practices, such as the use of standard precautions, the management of infectious waste, and the prevention of healthcare-associated infections

  5. Staff Qualifications and Training: This component includes a review of the HHA's staff qualifications and training, such as the qualifications of the administrator and clinical staff, and the provision of ongoing training and education

  6. Documentation: This component includes a review of the HHA's documentation practices, such as the maintenance of accurate and complete records, the documentation of services provided, and the accessibility and security of records

By following the HHA Survey Protocol, surveyors can ensure that they are conducting a thorough and effective survey of an HHA and evaluating the findings accurately.


How often are HHA survey protocols updated?

The Home Health Agency (HHA) Survey Protocol is updated periodically to reflect changes in regulations and standards. Here is what the search results show:

  1. The HHA Survey Protocol State Operations Manual (SOM) Appendix B was last revised on January 17, 2018

  2. The Home Health Agency (HHA) Survey Protocols document was last updated on an unknown date

  3. The Protocols and Guidelines Manual - Home Health CAHPS was last updated on January 15, 2023

  4. The Medicare Home Health Agency Survey and Certification Deficiencies report was published in 2001 and does not provide information on the frequency of updates to the HHA Survey Protocol

  5. The Home Health Agency Survey Instrument document does not provide information on the frequency of updates to the HHA Survey Protocol

  6. The 42 CFR Part 484 - Home Health Services regulation does not provide information on the frequency of updates to the HHA Survey Protocol

Based on the search results, it appears that the frequency of updates to the HHA Survey Protocol varies and may not be consistent across all documents.


What is Medicare Accreditation?

Medicare accreditation is a process by which an organization is authorized and credentialed to participate in the Medicare program and receive payment for services provided to Medicare beneficiaries. Here are some key points about Medicare accreditation:

  1. Accreditation is voluntary and is not required for Medicare certification or participation in the Medicare program

  2. Accreditation by an approved national accreditation organization (AO) can exempt providers and suppliers from routine surveys by state survey agencies to determine compliance with Medicare conditions

  3. Providers and suppliers that are accredited by an AO may be deemed to have met all applicable conditions by the Secretary of Health and Human Services

  4. CMS requires DMEPOS Medicare suppliers to attain accreditation to ensure industry standards are met and to maintain high levels of excellence in service and supplies

  5. All DMEPOS suppliers, unless otherwise exempted by supplier type, must be accredited by one of the eight CMS authorized accrediting organizations

  6. Health care organizations that want to participate in and receive payment from the Medicare or Medicaid programs must be certified as complying with the Conditions of Participation (CoPs) as set forth in federal regulations

  7. CMS grants "deemed status" to accrediting organizations to allow them to survey and "deem" that a health care organization meets the Medicare and Medicaid certification requirements through its accreditation process

  8. The HHA Survey Protocol provides guidance to surveyors on how to conduct a survey of an HHA and evaluate compliance with Medicare conditions

By understanding the key components of Medicare accreditation, providers and suppliers can ensure that they are in compliance with regulations and standards and can participate in the Medicare program.


What is the difference between Medicare certification and accreditation?

Medicare certification and accreditation are two different processes that healthcare organizations may undergo to participate in the Medicare program and receive payment for services provided to Medicare beneficiaries. Here are the key differences between Medicare certification and accreditation: Certification:

  • Certification is a process by which a healthcare organization is authorized to participate in the Medicare program and receive payment for services provided to Medicare beneficiaries

  • Certification is required for all new home health care agencies

  • Certification is based on compliance with the Conditions of Participation (CoPs) as set forth in federal regulations

  • Certification is granted by the Centers for Medicare and Medicaid Services (CMS) after a survey of the healthcare organization to determine compliance with the CoPs

  • Certification is required for healthcare organizations to participate in the Medicare program and receive payment for services provided to Medicare beneficiaries

Accreditation:

  • Accreditation is a voluntary process by which a healthcare organization is authorized and credentialed to participate in the Medicare program and receive payment for services provided to Medicare beneficiaries

  • Accreditation is not required for Medicare certification or participation in the Medicare program

  • Accreditation is based on compliance with industry standards and criteria set forth by an approved national accreditation organization (AO)

  • Accreditation by an AO can exempt providers and suppliers from routine surveys by state survey agencies to determine compliance with Medicare conditions

  • Accreditation is granted by an AO after a survey of the healthcare organization to determine compliance with industry standards and criteria

  • Accreditation is not required for healthcare organizations to participate in the Medicare program and receive payment for services provided to Medicare beneficiaries, but it can be beneficial for improving the quality of care provided.

By understanding the differences between Medicare certification and accreditation, healthcare organizations can ensure that they are in compliance with regulations and standards and can participate in the Medicare program.


What is the process for obtaining Medicare certification?

Here is the process for obtaining Medicare certification:

  1. Identify Potential Participants: The State Survey Agency identifies providers and suppliers that meet the requirements to participate in the Medicare or Medicaid programs

  2. Submit an Application: Providers and suppliers must submit an application to the State Survey Agency to participate in the Medicare program

  3. Survey: The State Survey Agency conducts a survey of the healthcare organization to determine compliance with the Conditions of Participation (CoPs) as set forth in federal regulations

  4. Certification: The State Survey Agency officially recommends its findings regarding whether healthcare entities meet the Social Security Act's provider or supplier definitions, and whether the entities comply with standards required by Federal regulations. Certification is granted when the State Survey Agency officially says that a healthcare facility is compliant with federal regulation standards

  5. Deemed Status: Healthcare organizations that are accredited by an approved national accreditation organization (AO) may be deemed to have met all applicable conditions by the Secretary of Health and Human Services. This can exempt providers and suppliers from routine surveys by state survey agencies to determine compliance with Medicare conditions

By following this process, healthcare organizations can obtain Medicare certification and participate in the Medicare program to receive payment for services provided to Medicare beneficiaries.


What are the steps to enroll as an institutional provider for Medicare certification?

Here are the steps to enroll as an institutional provider for Medicare certification:

  1. Obtain a National Provider Identifier (NPI): Institutional providers must obtain an NPI prior to applying for enrollment in the Medicare program. You can apply for an NPI on the National Plan & Provider Enumeration System (NPPES) website

  2. Complete the Medicare Enrollment Application: Institutional providers must complete the Medicare Enrollment Application (Form CMS-855A). The application can be submitted online through the Provider Enrollment, Chain, and Ownership System (PECOS)

  3. Pay the Medicare Application Fee: Institutional providers must pay the Medicare application fee, which is currently $595

  4. Submit Supporting Documentation: Institutional providers must submit supporting documentation, such as a copy of the license or certification, with the enrollment application

  5. Survey: Institutional providers must contact their local State Survey Agency to schedule a survey. The survey is conducted to determine compliance with the Conditions of Participation (CoPs) as set forth in federal regulations

  6. Certification: The State Survey Agency officially recommends its findings regarding whether healthcare entities meet the Social Security Act's provider or supplier definitions, and whether the entities comply with standards required by Federal regulations. Certification is granted when the State Survey Agency officially says that a healthcare facility is compliant with federal regulation standards

By following these steps, institutional providers can enroll in the Medicare program and receive payment for services provided to Medicare beneficiaries.


What is a MAC and how do I work with them during the enrollment process?

A Medicare Administrative Contractor (MAC) is a private health care insurer that has been awarded a geographic jurisdiction to process Medicare Part A and Part B (A/B) medical claims or Durable Medical Equipment (DME) claims for Medicare Fee-For-Service (FFS) beneficiaries. Here are the steps to work with a MAC during the enrollment process:

  1. Determine Your MAC: The first step is to determine which MAC is responsible for processing claims for your geographic area. You can find this information on the CMS website

  2. Contact Your MAC: Once you have determined your MAC, you can contact them to obtain information on the enrollment process and requirements

  3. Submit an Application: Institutional providers must complete the Medicare Enrollment Application (Form CMS-855A). The application can be submitted online through the Provider Enrollment, Chain, and Ownership System (PECOS)

  4. Pay the Medicare Application Fee: Institutional providers must pay the Medicare application fee, which is currently $595

  5. Submit Supporting Documentation: Institutional providers must submit supporting documentation, such as a copy of the license or certification, with the enrollment application

  6. Survey: Institutional providers must contact their local State Survey Agency to schedule a survey. The survey is conducted to determine compliance with the Conditions of Participation (CoPs) as set forth in federal regulations.

  7. Certification: The State Survey Agency officially recommends its findings regarding whether healthcare entities meet the Social Security Act's provider or supplier definitions, and whether the entities comply with standards required by Federal regulations. Certification is granted when the State Survey Agency officially says that a healthcare facility is compliant with federal regulation standards

By following these steps and working with your MAC, you can enroll in the Medicare program and receive payment for services provided to Medicare beneficiaries.


How long does it take to obtain Medicare certification?

The time it takes to obtain Medicare certification can vary depending on several factors, including the type of healthcare organization, the completeness of the application, and the time it takes to complete the survey. Here is what the search results show:

  1. The CMS-855 Enrollment Application Processing Timeframes document states that 100% of applications are completed within 65 calendar days of receipt

  2. The National Credentialing Services website states that Medicare will set the effective date as the date they receive the application, so even if it takes three months for them to complete an application, the provider will be retroactively covered

  3. The Medicare Provider Enrollment page on the CMS website states that providers must enroll in the Medicare program to get paid for providing covered services to Medicare patients. The page does not provide a specific timeline for the enrollment process

  4. The Provider Enrollment and Insurance Credentialing FAQ page states that the turnaround time for enrolling with Medicare as a DMEPOS supplier is 90-120 days

Based on the search results, it appears that the time it takes to obtain Medicare certification can vary depending on the type of healthcare organization and the completeness of the application. It is important to submit a complete application and work with the State Survey Agency to schedule a survey in a timely manner to avoid delays in the certification process.


What is the processing time for a completed Medicare enrollment application?

The processing time for a completed Medicare enrollment application can vary depending on several factors, including the type of healthcare organization, the completeness of the application, and the time it takes to complete the survey. Here is what the search results show:

  1. The CMS-855 Enrollment Application Processing Timeframes document states that 100% of applications are completed within 65 calendar days of receipt

  2. The National Credentialing Services website states that Medicare will set the effective date as the date they receive the application, so even if it takes three months for them to complete an application, the provider will be retroactively covered

  3. The Provider Enrollment and Insurance Credentialing FAQ page states that the turnaround time for enrolling with Medicare as a DMEPOS supplier is 90-120 days

  4. The Palmetto GBA website states that the average processing time for a paper application with no missing information is 14 days, while the average processing time for an internet PECOS submitted application with no missing information is 7 days

  5. The CGS Medicare website states that the current average processing time for a Medicare provider enrollment application is 30 days

Based on the search results, it appears that the processing time for a completed Medicare enrollment application can vary depending on the type of healthcare organization and the completeness of the application. It is important to submit a complete application and work with the State Survey Agency to schedule a survey in a timely manner to avoid delays in the certification process.


Is Medicare certification different by states?

Medicare certification requirements are the same across all states, as they are based on federal regulations and standards. However, the process for obtaining Medicare certification may vary slightly by state, as each state has its own State Survey Agency responsible for conducting surveys and certifying healthcare organizations. The State Survey Agency is authorized to set and enforce standards for Medicare certification, as well as for CLIA and Medicaid. The State Survey Agency may also partially re-delegate the functions to local agencies. Therefore, healthcare organizations should contact their local State Survey Agency to obtain information on the Medicare certification process and requirements specific to their state. By working with the State Survey Agency and following the federal regulations and standards, healthcare organizations can obtain Medicare certification and participate in the Medicare program to receive payment for services provided to Medicare beneficiaries.


Medicare Onsite Survey

I have just received my license to operate my home health agency. How do I obtain Medicare certification?

Congratulations on receiving your license to operate your home health agency! Here are the steps to obtain Medicare certification:

  1. Obtain a National Provider Identifier (NPI): Institutional providers must obtain an NPI prior to applying for enrollment in the Medicare program. You can apply for an NPI on the National Plan & Provider Enumeration System (NPPES) website

  2. Complete the Medicare Enrollment Application: Institutional providers must complete the Medicare Enrollment Application (Form CMS-855A). The application can be submitted online through the Provider Enrollment, Chain, and Ownership System (PECOS)

  3. Pay the Medicare Application Fee: Institutional providers must pay the Medicare application fee, which is currently $595

  4. Submit Supporting Documentation: Institutional providers must submit supporting documentation, such as a copy of the license or certification, with the enrollment application

  5. Survey: Institutional providers must contact their local State Survey Agency to schedule a survey. The survey is conducted to determine compliance with the Conditions of Participation (CoPs) as set forth in federal regulations.

  6. Certification: The State Survey Agency officially recommends its findings regarding whether healthcare entities meet the Social Security Act's provider or supplier definitions, and whether the entities comply with standards required by Federal regulations. Certification is granted when the State Survey Agency officially says that a healthcare facility is compliant with federal regulation standards

It is important to note that the process for obtaining Medicare certification may vary slightly by state, as each state has its own State Survey Agency responsible for conducting surveys and certifying healthcare organizations. Therefore, healthcare organizations should contact their local State Survey Agency to obtain information on the Medicare certification process and requirements specific to their state. By following these steps and working with the State Survey Agency, you can obtain Medicare certification and participate in the Medicare program to receive payment for services provided to Medicare beneficiaries.


What are the eligibility requirements for Medicare certification for home health agencies?

Here are the eligibility requirements for Medicare certification for home health agencies:

  1. Order from a healthcare provider: A doctor or other healthcare provider must order your care, and a Medicare-certified home health agency must provide it

  2. Part-time or intermittent skilled services: Medicare Part A (Hospital Insurance) and/or Medicare Part B (Medical Insurance) cover eligible home health services as long as you need part-time or intermittent skilled services

  3. Coordination of services: Usually, a home health care agency coordinates the services your doctor or allowed practitioner orders for you

  4. Medicare certification: The home health agency caring for you must be Medicare-certified

  5. Eligibility criteria: To be eligible for home health services, you must meet certain criteria, including being considered "homebound," needing intermittent care from skilled professionals, and having a plan of care established and reviewed by a doctor or other healthcare provider

By meeting these eligibility requirements and working with a Medicare-certified home health agency, you can receive home health services covered by Medicare.


What are the documentation requirements for Medicare certification for home health agencies?

Here are the documentation requirements for Medicare certification for home health agencies:

  1. Printed CMS 855A Home Health Enrollment Application or Online CMS 885A Home Health Enrollment Application

  2. CMS 1561: Health Insurance Benefit Agreement

  3. CMS 417 Request for Hospice certification, as applicable

  4. Verification of Office of Civil Rights Submission

  5. Plan of Care (POC)

  6. Certification/Recertification

  7. Face-to-face encounter documentation

  8. OASIS documentation

It is important to note that these are not the only documentation requirements for Medicare certification for home health agencies. Healthcare organizations should contact their local State Survey Agency to obtain information on the Medicare certification process and requirements specific to their state. By meeting the documentation requirements and working with a Medicare-certified home health agency, you can receive home health services covered by Medicare.


What are the documentation requirements for Medicare certification for home health agencies?

Here are the documentation requirements for Medicare certification for home health agencies:

  1. Printed CMS 855A Home Health Enrollment Application or Online CMS 885A Home Health Enrollment Application

  2. CMS 1561: Health Insurance Benefit Agreement

  3. CMS 417 Request for Hospice certification, as applicable

  4. Verification of Office of Civil Rights Submission

  5. Plan of Care (POC)

  6. Certification/Recertification

  7. Face-to-face encounter documentation

  8. OASIS documentation

It is important to note that these are not the only documentation requirements for Medicare certification for home health agencies. Healthcare organizations should contact their local State Survey Agency to obtain information on the Medicare certification process and requirements specific to their state. By meeting the documentation requirements and working with a Medicare-certified home health agency, you can receive home health services covered by Medicare.

 

Whether you're a seasoned provider or new to the HHA landscape, this guide is designed to address your pressing questions, help you sidestep common pitfalls, and arm you with the knowledge needed for a smooth survey experience. And remember, when in doubt or in need of professional support for a successful survey, don't hesitate to contact the Waiver Consulting Group. Reach us at 302-888-9172 or drop us an email at licensing@waivergroup.com.


We're here to help you achieve not just compliance but excellence in your HHA operations.

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