Surveys 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. HHAs must always be prepared for a surveyor visit since surveys may occur at any time, not just within the 36-month resurvey timeline.

Each Condition of Participation consists of multiple standards, which are assigned “G” tags. G tags are assigned to one of three levels, based on their impact on patient care:

• Level 1: Most related to patient care

• Level 2: Moderately related to patient care

• Level 3: Least related to patient care (all others)


The survey process begins as a Standard Survey with evaluation of compliance with the Level 1 standards. If compliance with all Level 1 standards is found, the survey ends. However,

if noncompliance is found, or noncompliance with additional conditions is suspected, the surveyor must proceed to a Partial Extended Survey. A Partial Extended Survey includes addition of evaluation of Level 2 standards, which are those moderately related to patient care, and may be extended to other related conditions at the surveyors discretion.

Deficiencies are defined as either standard level or condition level as follows:

• Standard level deficiency: Noncompliance with one or more of the standards that make up each condition of participation for HHAs.

• Condition-level deficiency: Any deficiency that substantially limits the provider’s or supplier’s capacity to furnish adequate care or which adversely affects the health or safety of patients

According to §488.24, the State Agency surveyor will certify that a provider is not in compliance with the CoPs where the deficiencies are of such character as to substantially limit the provider’s capacity to furnish adequate care, or which adversely affect the health and safety or patients


When substandard care is identified during a standard survey, defined as noncompliance with one or more conditions of participation at the condition-level, an Extended Survey ensues.

The Extended Survey reviews and identifies the HHA’s policies, procedures, and practices that produced the substandard care and may also review additional CoPs depending on the nature and extent of serious risk to patients that is identified in the standard survey. If the surveyor identifies or suspects an immediate jeopardy situation, (has caused, or is likely to cause, serious injury, harm, impairment, or death to a resident), the surveyor must follow guidance which could lead to immediate termination of an HHA.

In the event that a surveyor identifies the need for an Extended Survey, the following additional material may be examined in order to determine compliance with Level 2 Standards:

• Personnel records

• Contracts

• Policies and procedures

• Clinical/procedural references

• Documentation of home health aide training and/or competency evaluation

• Documentation of complaint investigation and resolution

• CLIA waiver (if any)

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