What Happens To Home Health & Hospice Surveys During The 2025 Government Shutdown?
October 15th, 2025
3 min read
By Abigail Karl

If you run or work in a Medicare-certified home health or hospice agency, the government shutdown may have you lying awake at night.
You may be wondering:
- What happens to your upcoming certification or recertification survey?
- What if your agency is in the middle of accreditation?
- Will application timelines be affected?
Take a deep breath. We’ll walk you through what we know as of now.
*This article was written in consultation with Mariam Treystman.
At The Home Health Consultant, we’ve advised dozens of Medicare-certified home health and hospice agencies on compliance, survey readiness, and accreditation transitions over the years. We stay ahead of regulation changes, and accreditor policies so that agencies don’t have to.
In this article, you’ll get a clear explanation of exactly what survey activities will and won’t proceed during the October 2025 federal shutdown for both home health and hospice.
Will ACHC, CHAP, Or TJC Surveys Occur As Scheduled During The Shutdown?
Yes, all surveys conducted by ACHC, CHAP, and TJC will continue during the government shutdown.
That means renewal, reaccreditation, and initial accreditation surveys for agencies working with accreditors are proceeding on normal timelines.
However, CMS’s processing of deemed-status paperwork (i.e., recognition of accreditation results) is paused until the shutdown ends. So while your accreditor can still survey your agency, CMS cannot officially recognize or activate your status until operations resume.
Will Complaint Investigations Still Happen For Home Health And Hospice?
Yes, complaint investigations will continue through the government shutdown.
If a complaint involves immediate jeopardy or credible evidence of serious harm, state surveyors are required to investigate. They may proceed without prior CMS approval during the shutdown. (Source: CMS QSO-26-01-ALL)
Less severe complaints that do not pose an immediate risk are deferred until CMS operations resume. This limited continuation ensures that patient safety remains protected despite the funding lapse.
Will State-Run Home Health Recertification Surveys Continue During The Shutdown?
The short answer is no: Routine home health recertification surveys by state health departments or other government entities are paused during the shutdown.
According to CMS’s QSO-26-01-ALL memo, standard Medicare-funded recertification surveys are classified as non-excepted (aka non-essential). So, they are suspended until the shutdown ends.
*However, in theory, a state with available non-federal funds could choose to continue conducting recertification surveys. But in practice, most states rely on CMS funding, meaning it’s still highly unlikely. (Source: CMS QSO-26-01-ALL)
Complaint investigations alleging immediate jeopardy or serious harm, however, remain in effect.
Will State Surveyors Continue Hospice Recertification Surveys During The Shutdown?
The short answer is yes: hospice recertification surveys will continue during the government shutdown. Hospice agencies have a special carve-out.
The Consolidated Appropriations Act of 2021 created mandatory funding for routine hospice surveys, making them “excepted” from the federal shutdown pause.
As confirmed in CMS’s QSO-26-01-ALL memo, hospice recertification surveys should continue on schedule even while other provider types are paused.
Still, complaint surveys remain prioritized for cases involving immediate jeopardy or harm. Lesser complaints may be deferred or reviewed as part of a regular recertification visit.
Will Initial Certification Surveys Be Conducted During The Shutdown For New Home Health Or Hospice Agencies?
There is no short answer to this question. The answer depends on if your agency is using state surveyors or an accrediting organization.
If your agency is using state surveyors:
No, initial certification surveys will not be conducted by state surveyors. New providers awaiting their initial Medicare certification survey cannot expect inspection during the funding lapse. (*Unless there is a serious complaint filed against the agency.)
If your agency is using ACHC, CHAP, or TJC surveyors:
Yes, initial certification surveys will be conducted by ACHC, CHAP, TJC through the government shutdown.
However, CMS will not process enrollment, issue a CMS Certification Number (CCN), or grant formal deemed status until the shutdown ends. This will create a delay in application processing timelines.
Home Health & Hospice Survey Status During the 2025 Government Shutdown
Here’s the bottom line when it comes to survey activity during the government shutdown:
- If your agency is accredited by ACHC, CHAP, or TJC:
There is no pause in survey operations. Accrediting organizations will continue conducting surveys as scheduled.
Note: CMS will not process new or renewed deemed-status approvals until the shutdown ends. - If your agency is surveyed by a state health department (state survey agency):
Routine home health recertification and initial certification surveys are paused until federal funding is restored.
The only exceptions are:- Hospice surveys, which continue as normal under dedicated mandatory funding.
- Complaint investigations, which will still be investigated.
- If your agency is awaiting initial Medicare approval:
You may still complete your accreditor’s survey, but CMS will not issue a CMS Certification Number (CCN) or activate your enrollment until after the shutdown.
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*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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