Waiting for a Medicare provider number can feel like the longest part of the process.
You passed your second survey. You did what was required. You expected the next step to be your provider number or a capitalization request. Instead, your agency may now receive a CMS walk-in visit called a provider validation survey.
That can feel confusing, especially when so much time and money is already tied to the outcome.
*This article was written in consultation with Mariam Treystman & Kelly McCarthy.
At The Home Health Consultant, we work with Medicare home health agencies through licensing, accreditation, compliance, and provider enrollment readiness. We created this article to help agencies understand:
- what this CMS validation survey means
- why it may be happening
- how to think about the next step in your compliance journey
The most important thing to know is this: a CMS provider validation survey is not automatically bad news.
In our recent webinar, we explained it this way: “If you get a CMS walk-in, this is a happy thing.” That is because, based on what we are seeing, this visit may mean your file is moving forward.
Who Is This CMS Provider Validation Survey For?
This article is specifically for Medicare home health agencies that have already passed their second survey and are waiting for their Medicare provider number.
In the webinar, we explained that agencies that completed second surveys earlier in the year had not yet received provider numbers as of June 2026. Agencies were waiting to see what would happen next. Now, CMS has started conducting validation surveys for all agencies in that stage.
That means the validation survey appears to be connected to the pending provider number process.
What Is A CMS Provider Validation Survey?
A CMS provider validation survey is a visit where CMS, through an independent contractor, double-checks the accreditor’s survey and verifies the agency.
In simple terms, CMS is validating that your agency:
- exists,
- is operational,
- and matches the information already submitted in the enrollment and licensing process.
During the webinar, we described it this way: “A validation survey is where they come and they double check the accreditor’s survey.”
That does not mean every validation survey will look exactly the same.
One important nuance is that these visits are being performed by CMS independent contractors. Because of that, the specific items requested may vary from person to person.
Some contractors may ask for only a few basic items. Others may ask for more. That variation is one reason agencies should understand the purpose of the visit before becoming alarmed.
Why Is CMS Doing Validation Surveys Before Issuing Provider Numbers?
Based on what we’ve seen over the past few weeks, CMS appears to be using these visits as an additional verification step before the provider number is issued.
The key point is that this does not appear to mean your agency is going backward.
It may actually mean the opposite.
In the webinar, we explained that “this is kind of good news because it means your case is moving on and moving forward towards getting a provider number.”
That is the mindset agencies should have.
The visit may feel stressful because it is another step. But it also suggests your agency has not been forgotten. CMS is actively reviewing and validating your agency.
As long as the validation survey goes well, your agency may be moving closer to the provider number.
Is A CMS Validation Survey The Same As Another Accreditation Survey?
No, a CMS validation survey is not the same as repeating your second survey.
Your accreditor already completed its survey. The CMS validation survey is CMS’s way of confirming certain information after that process.
The contractor may verify the physical location. They may confirm the agency’s NPI number. They may look at signage, basic office setup, census information, or other items. They may also take pictures, similar to other CMS site verification visits.
The point is not necessarily to perform a full clinical survey from the beginning.
The point is to validate that the agency is real, accessible, operational, and consistent with the information on file.
That difference is important because many agencies hear “survey” and immediately think of a full accreditation-style event. This visit is much shorter.
Who Comes To The Office For A CMS Provider Validation Survey?
The person coming to the office is a CMS independent contractor.
That matters because agencies may not always recognize the person or company name immediately.
Because different entities can conduct different types of visits, agencies should always identify who is at the office and where they are coming from.
A CMS validation survey is different from a state health department visit, an accreditor visit, or another type of site verification. Knowing who is there helps the agency understand what kind of visit is happening.
The agency should remain calm, professional, and prepared to answer basic questions.
What Is CMS Trying To Confirm During The Validation Survey?
During these validation surveys, CMS appears to be confirming that the agency is an operational home health agency with a legitimate physical office. Again, this includes confirming:
- The physical location
- Office signage
- Contact information
- NPI number
They may also ask who is in the office, what their role is, and whether the agency currently has active patients.
They may take pictures of the office, door sign, or posted items.
CMS is trying to see whether the business is operational and whether basic information is accurate.
For example, a working phone number is not a small detail. From CMS’s perspective, if a patient cannot call the number listed for the agency, that raises a serious concern.
The same logic applies to office hours, signage, staff presence, and basic agency information. These details help CMS determine whether the agency is truly functioning according to their standards.
Does The Agency Need Active Patients During The CMS Validation Survey?
No.
One important point is that it can be acceptable for an agency to have zero active patients while waiting for its provider number. Many agencies pause admissions during this stage for practical reasons.
Treating patients before the provider number is issued can be financially difficult. Agencies may not yet have access to the eligibility system. They may not be able to confirm whether a patient is already on service with another agency. They also cannot mark their place in the eligibility system.
That means another agency could potentially begin service, and the pending agency may not know. The agency may also be providing care without knowing whether it will be able to recover payment later.
For those reasons, some agencies choose not to admit new patients until the provider number is received.
However, agencies should still know their current census. If the census is zero, they should be able to clearly say that. If patients from the recent survey are still active, the agency should know that too.
The key is not whether the census is zero. The key is whether the agency can accurately explain its current status.
Why Does The Person Sitting In The Office Matter So Much?
The person in the office can affect how the visit goes.
CMS is not only looking at papers on the wall. Again, they are also observing whether the agency appears functional.
Someone must be physically in the office during business hours. It should not be a neighbor down the hall. It should not be someone “on call.” It should not be someone who does not understand their relationship to the agency.
When the person in the office cannot answer simple questions, it may make the agency look non-operational.
We explain more about who this person should be and what they need to know in the second article in this series, which will be posted next week.
Is It Okay To Work With A Home Health Consultant During This Process?
Yes. It is okay to work with a consultant, consulting company, or outside support team during surveys and throughout the process of opening and operating a home health agency.
The problem is when the agency cannot answer basic questions and responds as if the consultant knows everything and the agency knows nothing.
In our recent webinar, we explained that no one expects an agency to do everything completely alone. But CMS does expect the agency to understand basic information about its own business.
For example, the person in the office should not need to call a consultant to answer the agency’s phone number, staff roles, census, or where basic records are located.
Outside support can help an agency prepare. But the agency still needs to beknowledgeable and operational during the visit.
What Happens If The CMS Provider Validation Survey Goes Well?
Because CMS recently started conducting these provider validation visits, we can’t confirm the next steps with full confidence.
But we can share what we believe may come next, based on the traditional process we’ve seen after over 20 years in the industry.
One possible next step may be a capitalization request.
Before this recent change, the process usually moved from the provider certification kit being sent to NGS into a third capitalization request. That request checks the money in the agency’s bank account and requires documentation.
Agencies may receive communication from NGS after the validation survey. That communication could request capitalization documentation. It could also potentially lead toward the provider number, but the exact next step has not yet been confirmed.
*Because of that, agencies should watch closely for any NGS emails after the visit.
Should Home Health Agencies Be Worried About CMS Validation Surveys?
Agencies should take the visit seriously, but they should not panic.
Don’t get scared, get prepared. That is the right approach.
A CMS validation survey can feel intimidating because so much is riding on the provider number. But based on what we are seeing, the visit may mean the agency’s file is finally moving forward.
The agencies that are most likely to struggle are usually not the ones that calmly provide basic information. The bigger risk is when the office is empty, the phone does not work, signage is missing, staff cannot answer basic questions, or the agency appears inactive.
This is why preparation matters.
The visit may be brief. It may only involve a few questions and pictures. But the agency should be ready in case more is requested.
What Should Medicare Home Health Agencies Do Next?
First, understand what the CMS provider validation survey is.
It is a validation step. It is not automatically bad news. It may mean your agency is moving closer to its provider number.
Second, make sure your office is ready and stays ready before anyone walks in. We have another article breaking down exactly what you need below.
Finally, watch closely for any communication after the visit, especially from NGS. If a capitalization request or other instruction is sent, the agency should respond carefully and promptly.
In our next article, we break down exactly what agencies should check before a provider evaluation visit. This includes office signage, staff readiness, NPI access, census information, HR files, marketing materials, admission packets, and what to do when someone walks in.
Stay tuned and subscribe to our newsletter!
*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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