Few things bring more stress to a home health or hospice agency than survey day. You’ve worked hard to train your staff, keep your charts in order, and maintain compliance. But when surveyors walk through the door, it often feels like the weight of your agency’s future is on the line.
Here’s the truth: not all surveys are created equal. The approach taken by California Department of Public Health (CDPH) can feel very different from that of an accreditor.
*This article was written in consultation with Mariam Treystman.
At The Home Health Consultant, we’ve guided hundreds of Medicare-certified home health and hospice agencies through both CDPH and accreditor surveys. Our team has seen firsthand how these two types of surveys differ, and more importantly, how agencies can prepare for both.
By the end of this article, you’ll understand the different “mentalities” behind CDPH and accreditor surveys, so you can stay as ready as possible.
What Triggers a CDPH Survey vs. an Accreditor Survey in Home Health and Hospice?
The reason surveyors show up at your door often determines the tone of the visit.
- CDPH surveys usually happen when there’s a complaint investigation since California outsources most routine surveys to accreditors.
- Accreditor surveys are more routine. They’re conducted for initial enrollment, triennial renewals, and compliance check-ins after reportable changes.
Because each organization’s purpose is different, the entire survey experience feels different. Accreditors are verifying compliance. CDPH is digging deeper.
This difference in purpose leads directly into how each group approaches a survey once they’re onsite.
How Do Accreditors Approach Surveys in Home Health and Hospice?
Accreditors come in with a pass/fail mentality. They have a clear checklist and a defined scope. For example they typically:
- Review HR files for reportable positions, plus the field staff that surveyors visit, and one of each discipline
- Examine a sample of clinical charts
- Observe home visits
- Review Administrative Compliance elements, like QAPI and emergency planning/processes
Sometimes surveyors will tell you on the spot how things look after the survey. But the accreditor’s regulatory team ultimately makes the pass/fail decision after the survey is completed. They do this by reviewing what was tagged and mapping it to the correct standards.
All of the above makes the overall experience fairly predictable.
*Important Nuance: Accreditors are more generally incentivized to maintain professionalism and consistency (compared to CDPH) because you are their customer. If they closed every agency, they wouldn’t have a business. But this doesn’t mean accreditors won’t cite deficiencies, or won’t fail your survey.
Accreditors are contracted by CMS or local health departments, depending on your state and the type of survey. To maintain their contract, they have a strict set of rules to follow that come directly from the CMS and various health departments.
So, maintaining their surveying integrity is just as important as maintaining the customer base. It just means accreditors are more motivated to take an educational approach to surveys rather than a punitive one.
CDPH, on the other hand, is one of the big regulatory players that enforces the rules. Because of this, they don’t have to strictly follow a guide, checklist or rulebook to maintain a contract. They just have to do what the laws require.
How Does CDPH Approach Surveys in Home Health and Hospice?
CDPH approaches surveys with more of an investigatory mindset. While CDPH reviews the same items as accreditors, even when they aren’t there for a complaint, the mentality feels different.
They look at four main areas:
- Legitimacy: Is your agency real and operating lawfully? Is your Director of Nursing truly engaged, or just a name on the wall? Are visits being completed as documented?
- Patient Safety: Does the care you provide protect patients, or could it make things worse? Their priority is ensuring “do no harm.”
- Compliance: Are you following Medicare Conditions of Participation and California state regulations? Is your agency cutting corners?
- Care Quality: Is your agency providing services that actually improve patient outcomes?
*Accreditors also check for all of the above during your survey, but in the opposite order. Because CDPH often arrives at an agency for a complaint, they have to ‘diagnose’ the issue. ACHC on the other hand, is not trying to diagnose an issue, just complete a routine ‘wellness check’ of your agency’s compliance.
CDPH surveys feel less like “someone reviewing your work” and more like “someone investigating your operations.” Even if they’re not there for a complaint, they will still dig into legitimacy, safety, compliance, and quality.
In comparison to accreditors, it may seem like CDPH plays by no fixed rules:
- They can show up on a Friday at 4 p.m. and return Monday
- They can send one surveyor or five
- They might stay two days or seven
- They can even try to come back on a Saturday if they want
Unlike accreditors, CDPH doesn’t see you as a customer. If they close your agency, there’s no loss on their side.
This doesn’t mean CDPH is out there closing agencies for fun. Their main purpose is to protect patients and ensure the legitimacy of your agency. But, CDPH can still feel like the “wild, wild West” compared to the more structured approach of accreditors.
Regardless, CDPH surveys are completely free. This is why what’s often perceived as the more stressful option, is still a valid consideration for some agencies.
What Are the Risks of Swapping your Home Health or Hospice Accreditor for CDPH?
Some agencies are tempted to cancel their contract with their accreditor to save money. After all, accreditor survey fees often start around $9,000 every three years. With CDPH able to step in and perform triennial surveys for free, it can look like a cost-saving move.
But the trade-off is significant.
Accreditors bring:
- Structure
- Professionalism
- A degree of predictability
CDPH surveys, while free, come with:
- More uncertainty
- Longer timelines
- A deeper investigative lens
Before dropping their accreditor, agency owners should carefully weigh the risks against the financial savings.
How Can Home Health and Hospice Agencies Be Ready for Any Survey?
CDPH and accreditor surveys aren’t the same, and each brings its own mindset.
Accreditors rely on checklists and pass/fail standards, while CDPH digs into legitimacy, safety, compliance, and quality with fewer limits on how they conduct their reviews.
Regardless of which kind of survey walks through your doors, staying ready at all times is the best way to protect your agency. The first step to staying ready is education, and you’re already on the right track after reading this article. But don’t stop here.
To get step-by-step instructions on how to navigate the first 30 minutes of your next survey, read our guide ‘How to Prep for the First 30 Minutes of Survey’ below.
*Disclaimer: The content provided in this article is not intended to be, nor should it be construed as, legal, financial, or professional advice. No consultant-client relationship is established by engaging with this content. You should seek the advice of a qualified attorney, financial advisor, or other professional regarding any legal or business matters. The consultant assumes no liability for any actions taken based on the information provided.
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