If you own or operate a home health or hospice agency, the thought of a CMS site visit can be nerve-wracking. You don’t know exactly when it will occur, and a failed visit could delay or even deny your Medicare approval—jeopardizing your ability to serve patients and grow your agency.
At The Home Health Consultant, we’ve guided hundreds of home health and hospice agencies through the CMS site visit process. We’ve ensured they meet compliance requirements and avoid costly mistakes.
A CMS site visit may seem like a minor step in the Medicare accreditation process. However, it carries serious consequences. Many agencies are caught off guard by how quickly they can happen. The impact on your ability to operate can be significant.
In this guide, you'll learn:
- exactly what happens during a site visit
- why and when site visits occur
- how to make sure your agency is always prepared
By the end of this guide, you'll have a clear, step-by-step plan to ensure your agency is always prepared. You can pass CMS site visits with confidence and keep your Medicare accreditation on track.
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What is an Unannounced CMS Site Visit for Home Health & Hospice Agencies?
CMS site visits are conducted to verify that an agency is open and operational. These visits are nothing like a full accreditation, focus, or complaint survey. Site visits focus strictly on confirming your agency's physical location matches the information on file with Medicare.
Site visits are not an opportunity for surveyors to review patient records, HR files, or internal policies. Many agency owners hear the term "visit" and immediately assume they need to prepare for an in-depth survey of their entire operation. This is not the case.
CMS Site Visits are typically conducted by National Site Visit Contractors (NSVCs). There are two Site Visit Contractors in the United States as of the time of writing this article.
- Deloitte: Covers the Western side of the country
- Palmetto GBA: Cover the Eastern side of the country
As their name suggests, site visits contractors are not directly employed by CMS, but they are contracted by CMS. NSVCs conduct most site visits. But it is also possible for CMS to conduct site visits with their own staff as they see fit.
When and Why Do CMS Site Visits Happen?
CMS site visits don’t happen randomly. They are triggered by specific events. The most common situations where an agency may experience a site visit include:
- Initial Medicare Application: A CMS site visit may be conducted during this stage to ensure the agency is operational.
- Address Discrepancies: If there is any inconsistency in the agency’s location details, a CMS site visit may be ordered to verify the address.
- Third Round of Applications (Provider Number Request): All home health and hospice agencies can expect a CMS site visit at this stage.
- Location Change: Every time an agency moves, a CMS site visit will be conducted to verify the new location.
- Revalidations: CMS conducts site visits as part of the revalidation process to confirm an agency is still compliant with Medicare enrollment requirements. When an agency submits a revalidation application, a site visit is ordered.
After applying for Medicare certification, your agency may face an unannounced site visit at multiple points in the process. While you won’t know the exact date, you will receive an email alerting you of the general timeframe.
In California, these visits often happen within two weeks of the notice. Some agencies report visits occurring the very next day. For home health agencies that have submitted a Capitalization Request, a CMS site visit may be used to confirm that the agency has sufficient funds to operate. Agencies on a second CAP are less likely to receive a visit but should still be prepared.
Given the unpredictable nature of these visits, agencies should always be ready. The best way to ensure a smooth visit is to keep the office open during regular business hours. It is also important to maintain clear, visible signage that matches the details in the agency’s application.
What Do National Site Visit Contractors Look For During a Site Visit?
When a CMS site visit occurs, a National Site Visit Contractor arrives at the agency's location to verify specific details. The process is quick and typically involves:
- checking for proper signage (see more on this below)
- confirming that the agency is open
- taking photos of the entrance
- making sure the office is furnished
- ensuring there are no eviction or ‘for lease’ notices
- confirming that no other business is operating out of your agency’s office unit
- verifying your accreditation/license is displayed on the agency office wall
A NSVC does not interact with patients or staff beyond verifying that the business is operational, meaning “open for business.” For your agency to be considered open and operational, your office must be accessible to the public and a staff member must be present.
Additionally, we’ve seen rare instances of inspectors asking to take photos of your agency’s accreditation or license. So make sure you have these documents accessible just in case.
Because the visit is unannounced, it is possible for an inspector to come and go without agency staff even knowing they were there. The agency might not find out about the visit until they receive an approval or denial letter from Medicare.
Unlike a traditional survey, no one from leadership is required to be present for a CMS site visit. However, again, someone must be available to confirm that the agency is open. This can be an administrative assistant, office manager, or any other employee.
To learn more about what your agency’s physical location needs to be green lit by CMS, read our article on Lease and Office space requirements below.
What to Expect After a Home Health Site Visit: Approval or Denial?
Your CMS site visit has occurred, whether you realized it or not. After the visit, agencies will receive one of two outcomes: approval or denial.
Agencies will know the results of their site visit through official notification from their Medicare Administrative Contractor (MAC). The decision will be communicated via email or mail.
If the CMS site visit was successful, the approval notice will outline the next steps in the enrollment process. If the agency was denied, the notice will include the reason for the denial and any corrective actions required.
Some agencies only find out about the visit when they receive their determination letter. This makes it very important to monitor email and postal mail closely after receiving notice of a potential site visit.
What Can Cause a CMS Site Visit Denial?
If approved, the agency moves forward in the Medicare or Medicaid enrollment process without issue. But if denied, large and expensive issues can arise.
Common reasons for failure include:
- Vacant or Unoccupied Office: If the listed address is empty, closed, or marked “For Lease,” CMS considers the agency non-operational.
- Lack of Business Activity: Even if signage is present, no visible business operations during posted hours can result in a failed site visit.
- Incorrect or Misleading Location Information: If an unrelated business is found at the listed address or the agency is using a virtual/co-working space that only receives mail, CMS may issue a denial or revocation.
- Refusing a Site Visit: Rejecting a site visit can result in the denial or revocation of your Medicare billing privileges
- Failure to Report Address Changes: Agencies must update their Medicare Administrative Contractor (MAC) within 30 days of any location change. Delays in updating practice location details can trigger administrative actions.
Agency location can greatly affect your compliance with CMS regulations, in more ways than one. To learn more and stay compliant, read our article on Geographical Service Areas below.
The best way to avoid a denial is to ensure that the agency is visibly open. Don’t forget, your agency address must match the information provided in the application. Again, there should always be someone available to confirm business operations.
What Happens If My Home Health or Hospice Agency Fails a CMS Site Visit?
If CMS determines the agency is non-operational, it may face one of the following depending what triggered your agency’s site visit:
- Denial of Enrollment: If a new applicant fails a site visit, their enrollment request may be denied.
- Revocation of Billing Privileges: Existing providers found non-compliant may have their Medicare billing privileges revoked.
- Deactivation of Medicare Billing: CMS may deactivate an agency’s billing privileges if it is temporarily non-operational.
If your agency is denied, your next steps will depend on the severity of your failure. You’ll either need to restart your application, submit a corrective action plan, or submit a reconsideration request. This can set your approval back by weeks or even months.
Pro Tip: Governing entities rarely reverse their initial decision on whether you pass or fail. This makes it even more critical to understand your responsibilities and ensure your agency meets the required standards.
How to Stay Prepared for Your Home Health or Hospice Agency’s Site Visit
Passing a CMS site visit is essential for your home health or hospice agency to operate successfully. While these visits are unannounced, they don’t have to be stressful if you’re prepared.
Many agencies face unexpected denials simply because:
- their signage wasn’t visible
- their office was closed
- their address didn’t match official records
Avoid these mistakes by keeping your agency open during posted hours and ensuring all details are up-to-date. Below you’ll see an example of what information should be included on proper agency signage.
Passing your site visit is one of the most simple aspects of the Medicare accreditation process. Because of this, it can get overlooked, or its importance can be underestimated. Although a CMS site visit is a simple, quick process, it's an essential step in getting your accreditation. Don’t leave your approval to chance. Stay proactive to ensure your agency is always ready.
At The Home Health Consultant, we’ve helped hundreds of home health and hospice agencies successfully navigate the Medicare accreditation process. While we’re not currently accepting new agencies for accreditation applications, we’re committed to equipping you with the knowledge you need to succeed.
Your next step is to gain a deeper understanding of all types of regulatory visits. Read our comprehensive guide on the different types of surveys your agency may face. Click below to stay informed and ahead of the curve.
*This article was written in consultation with Kelly McCarthy & Mariam Treystman.
*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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