Maintaining regulatory compliance is no easy feat. From adhering to Medicare CoPs, state regulations, and accreditor standards, it can be difficult to keep track of what your agency needs to do and for who. If you’ve been agonizing over how to stay compliant, knowing what changes in your agency you need to report is a great place to start.
At The Home Health Consultant, we specialize in helping agencies stay compliant. With over 20 years of experience, we’ve processed countless applications, guided agencies through compliance hurdles, and ensured operational success. Today, we’re shedding light on an often-overlooked but critical topic: reportable changes.
By the end of this article, you’ll leave with:
- A comprehensive list of all reportable changes
- Knowledge of what changes need to be reported to which regulatory bodies
- A solid understanding of how to keep your agency compliant among changes
Why Reporting Changes in Home Health & Hospice Matters for Compliance
Home health and hospice agencies operate in a heavily regulated industry. Reporting key changes is not just a formality—it’s a requirement. Reportable changes include significant modifications to an agency’s:
- operations,
- ownership,
- or staff.
These changes must be communicated to the appropriate governing agencies. Most of the these changes are required to be reported to:
- California Department of Public Health (CDPH)
- Your Medicare Administrative Contractor (MAC)
- Your Accrediting Organization (AO)
There are also different reporting requirements between home health & hospice agencies.
Failure to report changes can lead to:
- Delays in processing applications
- Suspension or termination of Medicare certification
- Financial penalties or loss of revenue
- Potential shutdown of operations
The consequences of failing to meet reporting requirements can vary. They depend on the seriousness of the error and the specific governing agency involved.
Types of Reportable Changes for Home Health & Hospice Agencies
The types of reportable changes can be separated into four categories. These categories include:
- key staff changes
- ownership and structure changes
- location and name changes
- operational changes
Under each of these categories, there are specific applications for each type of change. By understanding these applications and their names, you can stay on top of compliant reporting.
1. Key Staff Changes
The reporting requirements for key staff changes specifically are constantly changing. While this information is up-to-date as of February 2025, always check CDPH and CMS for the current reporting requirements.
Home Health Staff Reporting Requirements
As of February 2025, the key staff reporting requirements for home health are as follows:
- CHOA: Change of Administrator — Report to CDPH
- CHAD: Change of Administrator Designee — as of February 2025, CDPH is not processing change of administrator designee. Even if you report it, it will not make its way into their system.
- DPCS: Change of Director of Patient Care Services — Report to CDPH
- DPCSD: Change of Director of Patient Care Services Designee — This is not a reportable position for any governing agency, but is a required position.
Hospice Staff Reporting Requirements
As of February 2025, the key staff reporting requirements for hospice are as follows:
- CHOA: Change of Administrator— Report to CDPH & your MAC (typically NGS in California)
- CHAD: Change of Administrator Designee— Report to CDPH
- DPCS: Change of Director of Patient Care Services— Report to CDPH
- DPCSD: Director of Patient Care Services Designee— Report to CDPH
- CHMD: Change of Medical Director—Reported to CDPH & your MAC
- Medical Director Designee: This is not a reportable position for any governing agency, but is a required position.
2. Ownership and Structure Changes
Reporting ownership changes is incredibly important in healthcare. It protects patients and maintains accountability in the industry.
Regulatory bodies use this information to make sure that quality standards remain consistent regardless of ownership changes. Here are the specific changes you must report:
- CHOW: Change of Ownership (50% or more)—Reported to CDPH, MAC, and Accrediting Organization (AO). In California, this change can trigger an onsite focus survey. A change of ownership involves strictly enforced submission timeline regulations.
- CHST: Change of Stock Transfer (49% or less)—Reported to CDPH, MAC, and AO. In California, an application with a stock transfer and location change together can trigger an onsite focus survey.
- CHIO: Change of Indirect Ownership—Parent company changes reported to CDPH, MAC, and AO.
A change of ownership is one of the most important reportable changes. Failure to report a change in ownership, or reporting it incorrectly, can quickly lead to your agency being shut down. To read more about how to navigate changes in ownership, check out our article on the 36-month rule.
3. Location and Name Changes
Moving your agency or changing its name might seem straightforward, but it requires careful planning. These changes affect your patients, staff, and regulatory compliance.
Location changes need thorough review to ensure your new space meets all healthcare requirements. Even a mailing address change needs proper documentation. Here are the specific changes you need to report:
- CHOL: Change of Location—Reported to CDPH, MAC, & your AO. In California, this change can trigger an onsite focus survey. Location changes also trigger CMS site visits.
- CHMA: Change of Mailing Address—Reported to CDPH, MAC, and AO.
- CHON: Change of Agency’s Name—Reported to CDPH, MAC, and AO.
- CGSA: Change of Geographical Service Area—Reported to CDPH, MAC, and AO
4. Operational Changes
While you can adjust many internal processes without reporting them, some operational changes must be officially documented. If you change your NPI, services, property ownership, or provider number, you need to notify the right governing bodies.
Failing to report these updates can cause compliance issues or billing delays. Each type of change has specific reporting requirements:
- CNPI: Change of NPI—Reported to CDPH, your MAC, and your AO.
- CHOS: Change of Services—Reported to CDPH and AO for service modifications.
- CHPO: Change of Property Owner—Reported to CDPH.
- CHOC: Change of Provider Number (PTAN)—Reported to CDPH.
Pro Tip: Even though it’s not a reportable change, be sure to keep your agency’s contact information up-to-date with all regulatory agencies. Failure to receive or respond to important messages from any governing agencies could result in penalties against your agency.
To change your contact information with your MAC, visit the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) online portal to modify online. To change your contact information with CDPH and for most accreditors, simply sending them an email with the updated information will suffice.
Who to Report Home Health & Hospice Changes To (and When)
Reporting Entities
There are three main entities your agency will have to report changes to, depending on the type of change. Each governing agency plays a different role in ensuring compliance.
- CDPH: California Department of Public Health oversees state compliance.
- MAC: Medicare Administrative Contractors like NGS manage federal certifications.
- AO: Accrediting Organizations validate compliance with standards.
To read more about how these governing entities interact with each other, check out our article ‘The Home Health & Hospice Industry Structure Explained’.
Reporting Timeframes for Home Health & Hospice Agencies
Agencies should aim to report most changes within 10-30 days of occurrence. However, each change has its own reporting timeframe. These time frames can change according to internal policies in CDPH and CMS.
Processing times vary but typically range from 4 months to over a year, depending on the complexity. To find the most current application processing timelines, please visit our sister company’s Instagram @my_sbs_group.
What Happens If You Don’t Report Changes in Home Health & Hospice?
Failing to report changes can shut down your agency. For example, an agency could lose its CDPH license and Medicare certification simply because ownership paperwork wasn’t filed on time. For hospices, missing an administrator change can deactivate Medicare billing. These costly mistakes are 100% avoidable—if you know what to report and when.
Reporting changes in home health and hospice isn’t just paperwork — it’s critical to keeping your agency running. Staying compliant is completely achievable with the right guidance.
If you still have questions about reportable changes, click below to read our article on ‘Everything You Need to Know About GSA’ below.
*This article was written in consultation with Mariam Treystman & Kelly McCarthy.
*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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