Home health agencies (HHAs) are required to meet the definition of an HHA in section 1861(o) of the Social Security Act (the Act) as well as be in compliance with the Federal requirements set forth in the Medicare Conditions of Participation (CoPs) in order to receive Medicare/ Medicaid payment. The goal of the HHA survey is to determine if the agency is in compliance with the CoPs set forth at 42 CFR Part 484.
The HHA survey process incorporates an approach that 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. Through the survey process, surveyors determine if the HHA has the ability to meet minimum health and safety standards, deliver needed patient services and, most importantly, if the delivery of those services impacts the quality of care and results in positive patient outcomes.
The purpose of this guide is too direct HHAs to the survey protocols and guidance surveyors use to prepare for the survey, conduct the survey, and evaluate the survey findings. Survey survival and avoidance of deficiencies depends on a HHA’s ability to remain in continuous compliance with the CoPs, understand the survey process, and know their rights during and after a survey. Sanctions, which went into effect in 2013, can be imposed when survey deficiencies indicate substandard care. Sanctions include:
1) civil money penalties,
2) suspension of payment for all new admissions,
3) temporary management of the HHA,
4) directed plan of correction, and 5) directed in-service training.
Continuous, substantial compliance with the CoPs is essential to avoid sanctions, which can result in disruption of HHA operations and cash flow.