A CMS walk-in visit can turn an ordinary office day into a high-stakes moment.
Your agency may have already passed the second survey. You may be waiting for your Medicare provider number. You may also feel unsure about what CMS wants to see, what your staff should say, and whether a small office issue could affect the next step.
That is exactly why preparation matters.
*This article was written in consultation with Mariam Treystman & Kelly McCarthy.
At The Home Health Consultant, we help Medicare home health agencies prepare for licensing, accreditation, compliance, and provider enrollment milestones. We created this article to help agencies understand what should be ready before a CMS provider validation survey happens, based on what we discussed in our recent webinar.
The main message is simple: Don’t get scared, get prepared.
A CMS provider validation survey may be short. It may only involve a few questions. But your agency should still be ready for more than the minimum.
Who Should Be In The Office During A CMS Provider Validation Survey?
Someone must be physically present in the office during business hours.
It is not enough for someone to be nearby. It is not enough for someone to be “down the hall.” It should not be a neighbor, friend, or unrelated person watching the space.
The person in the office should be an employee of the agency.
That means they should have an HR file. They should understand their role. They should know they are there as part of the agency, not just helping as a favor.
This matters because during a provider evaluation visit, CMS is trying to confirm that the agency is operational. While most agencies view the moment between the Medicare Deemed status survey and the provider number as a “waiting period”, CMS views the agency as an active company that should be running. When a surveyor or CMS contractor walks in during posted office hours, the office should look and feel like an active home health agency. This is why it is absolutely essential to have someone at your office, even if you’re not accepting new patients yet.
In our recent webinar, we explained that CMS may extend a courtesy and call the office if no one is there. They may come back later. But they also may not, and simply deny the entire application. The safest approach is to have someone physically seated in the office during business hours.
What Should The Person In The Office Know Before CMS Arrives?
The person in the office does not need to be the top expert in home health.
But they do need to know basic agency information.
CMS may ask who they are, what their role is, who works for the company, and whether the agency has active patients. The person should be able to answer those questions calmly and accurately.
At minimum, they should know:
- Their own job title
- That they are an employee of the agency (not helping their cousin during summer break)
- Who the Administrator is
- Who the DPCS is
- Who the designees are
- Who the official owners are
- Whether the agency has active patients
- Where basic records or lists are kept
This is especially important when the person sitting in the office is not deeply involved in daily operations. If that person is mainly there to answer the phone and open the door, their HR file should match that reality. A lower-level title, such as receptionist, may be more appropriate if that is the actual role.
The goal is to make sure their role is accurate, documented, and understood.
Why Does The Agency Phone Number Need To Be Checked Before The Visit?
A working phone number is critical.
This may sound like a small detail, but it can have a big consequence. CMS may call the number listed for the agency. They may also compare the phone number on the door sign, wall signs, marketing materials, admission package, and applications.
The number should be accurate. It should work. Someone should be able to answer it.
During our recent webinar, we shared an example where an agency believed its phone was working, but it had been disconnected. That kind of issue can create serious problems because CMS may ask how patients are supposed to reach the agency if the listed number does not work.
Before a validation survey, agencies should physically test the phone.
Do not assume it works because it worked before. Call it. Confirm it rings. Confirm the right person can answer. Confirm voicemail, forwarding, and contact details are functioning correctly.
If the agency has changed its phone number, email, fax, or other contact information, that information should match the appropriate applications and official records. If something needs to be updated, the agency needs to file applications with governing authorities promptly and be sure to update all agency materials to reflect the correct information.
What Signs Should Be Posted In The Office For A CMS Provider Validation Survey?
CMS may look at office signage and take pictures.
The door sign is especially important because it helps confirm the physical location, office hours, and phone number. The information on the door sign should match the information CMS has for the agency.
Inside the office, several wall signs should be posted and current.
Agencies should make sure the following items are up and accurate:
- Current state license
- Accreditation certificate
- Current labor law poster
- Organizational chart
- GSA or service area map
- Complaint process sign
The license should be current and active. If the license is expired, the agency should address that immediately.
If the license is expiring soon and renewal has not been submitted, the agency should not ignore it. License renewals can take time to process, so it’s always better to stay ahead of the renewal rather than trying to catch up to it. Please have renewal copies on hand if you have not received your updated license yet.
The accreditation certificate should also be posted. Agencies waiting for a provider number may have received this certificate by email. It does not need to be a fancy paper copy. It just needs to be available and posted.
The labor law poster should also be current for the year. If you have an outdated labor last poster, even from last year, this will be flagged.
These details help CMS see that the office is active, compliant, and ready.
What Is The Difference Between The NPI, PTAN, And State License Number?
CMS has commonly asked agencies to verbally confirm the NPI number.
This is the National Provider Identifier. It is not the PTAN. Agencies waiting for their provider number do not have the PTAN yet.
It is also not the state license number.
This can be confusing because agencies may have several long numbers connected to the business. The person in the office does not need to memorize the NPI. But they should know where to find it quickly.
The NPI is something the agency received very early in the process. It should already exist before the provider application is submitted.
Before CMS arrives, the agency should make sure the NPI is easy to locate, and that the employee in your office knows where and how to find it.
What Documents Should Be Ready For A CMS Provider Validation Survey?
Because CMS provider validation surveys are new and CMS is using independent contractors for the visits, the exact requests may vary.
Some CMS validation visits may involve only a few basic questions and pictures. Others may involve more document requests. That is why agencies should prepare more than just the items they think will be asked.
In the webinar, we explained that “you want to be the two, three things people, not the 15 things people.” In other words, the more prepared and confident the agency appears, the smoother the visit may go.
Agencies should be ready to access:
- Current staff list
- Current active census
- HR files (can be either paper or electronic)
- Admission package
- Marketing materials
- Policies and procedures
- Patient files or chart location
The staff list should include key agency personnel, such as the Administrator, DPCS, designees, and clinical staff even if the agency is not actively admitting new patients.
The active census should also be clear. If the agency has zero active patients, staff should be able to say that. If there are still active patients from the recent survey period, staff should know that too.
The admission package and marketing materials should also be checked before the visit. Again, you should confirm that phone numbers, emails, fax numbers, addresses, and other contact information are accurate and working.
Where Should Patient Files Be Kept During The CMS Visit?
During a CMS provider validation visit, CMS may ask where patient files are kept.
Many agencies in this stage may still have paper charts. If the charts are paper, they should be kept in a lockable filing cabinet.
If the agency uses electronic records, the person in the office should know how those records are accessed. The agency should also have a computer and internet access available.
The larger point is that the agency should be able to show how patient information is stored and protected.
A home health agency office should not appear empty or disconnected from its records. If CMS asks where charts are kept, the person in the office should be able to answer without confusion.
What Should The Office Look Like During A CMS Provider Validation Survey?
The office should look like a functional office, that’s what CMS is there to check.
This does not mean it needs to be fancy. It does not mean it needs to be large. But it should look operational.
Many providers use this waiting period to update their furniture, technology and supplies. Please wait until after CMS conducts their visit to do projects like this.
CMS may take pictures during the visit. If the office has no desk, no chair, no computer, no printer, no cabinet, and no visible signs of activity, that may create concern.
The webinar emphasized that an operational office should generally have all the items you passed survey with:
- Desks
- Chairs
- Office supplies
- Computer
- Printer
- Internet access
- Lockable filing cabinet
- Fire extinguisher
A computer is especially important if the agency keeps policies, procedures, HR documents, or other materials electronically. It would be difficult to explain that records are online if there is no way to access them from the office.
The office should also have basic supplies that support normal business activity. CMS is looking to see whether this is a real and functioning agency location.
Does The Agency Need Medical Supplies In The Office?
In our recent webinar, we explained that it may be okay not to keep medical supplies in the office, here’s why.
Some agencies order patient-specific supplies when a patient needs them. For example, supplies may be drop-shipped when a case requires them.
However, if the agency does keep medical supplies in the office, it should manage them properly.
Basic medical supplies may include items such as gloves, normal saline, wound care supplies, or hand sanitizer. If supplies are stored in the office, the agency should check expiration dates regularly.
We want to emphasize the importance of monthly expiration checks if you are storing medical supplies in your office.
What Should Staff Do When Someone Walks In For A CMS Visit?
The person in the office should stay calm and professional.
They should first identify who has arrived.
We advise agencies to ask for a business card. If the person does not provide one, ask to see a badge. Then write down the person’s name and where they are coming from.
This matters because different entities may visit an agency for different reasons, resulting in different kinds of surveys. A CMS contractor visit is different from a state health department visit. It is also different from an accreditor visit.
The agency should know who is in the office before assuming what type of visit is taking place.
Once the person is identified, the agency representative should notify the appropriate internal contact or support team. But staff should avoid creating the impression that no one at the agency knows basic information.
Examples of things the employee can say after confirming the person’s identity are, “Great thanks for confirming where you’re coming from, and welcome to our agency. Please excuse me for just a moment. I’m going to call our DPCS and Administrator and let them know you’re visiting. I’m more than happy to help you find anything you need.”
There is a difference between calling for support and being unable to answer simple questions.
What Should Staff Avoid Saying During A CMS Provider Validation Survey?
Again, it is okay to work with outside support during your home health enrollment process and during surveys. But it is not okay for staff to act as though the outside support knows everything and the agency knows nothing.
Many agencies use consultants, vendors, advisors, or outside compliance support. That is not the issue. The issue is when CMS asks basic agency questions and the person in the office repeatedly answers, “I don’t know, my consultant handles that, my coder handles that....” That can make the agency look disconnected from its own operations.
The person in the office should be able to answer basic questions such as:
- What is the agency phone number?
- Who is the Administrator?
- Who is the DPCS?
- Who owns the company?
- What is the current census?
- Where is the staff list?
- Where are HR files?
- Where are patient charts kept?
These are not hyper-specific clinical questions. They are basic operational questions. Staff should answer clearly, calmly, and truthfully.
Why Does Confidence Matter During A CMS Validation Survey?
Confidence can affect how the visit feels and how smoothly it moves.
In the webinar, our applications department head, Kelly, explained, “Calmness and confidence goes a long way.”
That does not mean staff should pretend to know things they do not know. It means they should be prepared enough to answer basic questions without panic.
When staff appear unsure, call multiple people, cannot locate documents, or seem afraid to answer, the visit may become more complicated. The contractor may start asking more questions because the office does not appear prepared.
When staff calmly provide the NPI, staff list, census, HR files, or other requested items, the visit may move faster.
Surveyors and contractors usually have a checklist. They need to verify items, take pictures if needed, and complete their work. Prepared agencies help that happen.
In cases where agencies have been flagged during these or similar visits, most of the time the agency was fully prepared. But anxiety and nerves can spike in these moments, and surveyors or site visitors can pick up on that energy.
Remember, these people are not out to get you, they are simply doing their job, which is to make sure you’re doing yours.
If you’ve been staying ready, and keeping the employee sitting in your agency educated and aware, you’re on the right track and can face these visits with calmness and confidence.
How Can Agencies Prepare Staff Before The CMS Walk-In Visit?
Agencies should not wait for the walk-in visit to train the person sitting in the office.
Before the visit happens, the agency should review the basics with that person. Even if you’ve reviewed this information at hire, a short practice run can help.
Ask the person:
- What is your title?
- Who is the Administrator?
- Who is the DPCS?
- Who are the designees?
- Who are the owners listed on the paperwork?
- What is the current census?
- Where is the NPI?
- Where is the staff list?
- Where are HR files?
- Where are patient files kept?
- What do you do if someone from CMS walks in?
The person should also know how to access the computer, internet, printer, and any electronic files that may be needed.
If the person has free time while sitting in the office, use that time to build basic home health knowledge. In the webinar, we recommended having them watch educational resources from The Home Health Consultant so they can better understand home health basics.
They do not need to master everything. But they should be comfortable with the agency’s basic operations.
What Should Agencies Check Every Morning While Waiting For CMS?
During this waiting period, agencies should treat each business day as a possible visit day. A simple morning review can prevent avoidable problems.
Before or at the start of business hours, confirm:
- Someone is physically in the office
- The office phone works
- The door sign is visible and accurate
- Required wall signs are posted
- The license is current
- The accreditation certificate is posted
- The labor law poster is current
- The NPI is easy to find
- The staff list is available
- The census is current
- HR files can be accessed
- Admission packets are available
- Marketing materials have accurate contact information
- Patient files are secured and accessible if requested
- The computer, printer, and internet work
- The office looks functional and professional
These are basic checks, but they matter.
Many problems during site visits come from small issues that could have been fixed earlier.
What Should A Home Health Agency Do To Stay Ready For A CMS Provider Validation Survey?
A CMS provider validation survey may only take a few minutes. But for an agency waiting on a provider number, those few minutes matter.
The best preparation is not complicated. Have someone physically in the office. Make sure that person is an employee with an HR file. Confirm the phone works. Post the correct signs. Know where the NPI is. Keep basic documents accessible. Make the office look operational. Stay calm when someone walks in.
Most importantly, do not let the office appear disconnected from the agency’s operations.
The person in the office does not need to know every detail of Medicare home health. But they should know the agency’s basic facts and where important information is kept.
That preparation can make the difference between a stressful, confusing visit and a smooth validation process.
At The Home Health Consultant, we take pride in ensuring our clients know about sudden CMS changes and updates like these so they are never caught off guard and always prepared for whatever comes next.
We have an entire office of incredible consultants and have been in the industry for over 20 years. To learn more about our company, our philosophy, and how we can help your agency, watch a few of our Client Testimonials or check out our How We’re Different page.
*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.
Topics:
