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 what survey activities will and won’t proceed during the October 2025 federal shutdown for both home health and hospice.
*IMPORTANT NOTE: This is an actively changing situation. We always try our best to keep our content up to date, but for the most current information, always check the CMS website.
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 as normal.
However, processing of accreditation applications, even after passing your survey, may be delayed. More on this below.
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?
It's complicated. For the most part, routine home health recertification surveys by state health departments or other government entities are paused during the shutdown.
However there are a few exceptions:
- States May Choose to Fund Their Own Surveys: According to CMS’s QSO-26-01-ALL memo, standard Medicare-funded recertification surveys are classified as non-excepted (aka non-essential).
Most state health departments receive significant funding from the federal government.*However, in theory, a state with available non-federal funds could choose to continue conducting recertification surveys. But in practice, most states rely on federal funding, meaning it’s still unlikely. (Source: CMS QSO-26-01-ALL)
- Surveys That Would Prevent Medicare Termination: Agencies that are at risk of Medicare certification termination should still expect a survey, even if they are being surveyed by the state.
In this case, the situation would need to meet the three requirements below:
(a) An agency claims they have corrected previous deficiencies and now meet CMS requirements, and
(b) A revisit is needed to verify compliance in order to avoid a scheduled Medicare termination, and
(c) The termination is likely to happen soon due to timing or specific circumstances.
And again, to clarify, complaint investigations alleging immediate jeopardy or serious harm remain in effect and will continue.
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” (aka an exception) 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 until the end of the shutdown.
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 your state chooses to use state-only funding.)
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.
Will Medicare Certification Applications Be Processed During the 2025 Government Shutdown
To answer this question, you first need to understand the steps to getting your Medicare accreditation approved. If you haven’t already, we highly recommend reading our article on the home health & hospice industry structure before continuing.
Here are the steps to getting your Medicare certification approved, very generally laid out, for a big picture idea:
Step 1: You pass your initial accreditation survey
Step 2: You send your application with your initial survey results to your state health department
Step 3: Your state health department reviews your application
Step 3: After reviewing, your state health department sends your application to your local MAC
Step 4: Your MAC reviews and approves your application
Per CMS’s QSO-26-01-ALL memo, applications that were submitted to your local health department before October 1st (the first day of the government shutdown), are expected to be processed.
Any applications sent on or after October 1st, will not be processed until after the shutdown ends. This is true even if you pass your initial accreditation survey during the shutdown.
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. - If your agency is surveyed by a State Health Department:
It depends on the type of survey and whether your agency is a home health or hospice.
If you want the latest updates on compliance, regulatory changes, and updates like this one, join our biweekly newsletter for home health and hospice leaders.
You’ll get short, practical insights straight to your inbox — including industry news, resource guides, and policy explainers written by our compliance experts.
Sign up for The Home Health Consultant Newsletter here.
*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:
