If you’re running a new home health or hospice agency in California, you’ve likely encountered the term Geographical Service Area (GSA). Maybe you wondered, “What does this actually mean for my agency?” If you don’t fully understand these regulations, you could unknowingly limit your ability to expand, take on referrals, or even operate legally in California.
Understanding GSA isn’t just a box to check—it’s a critical component of staying compliant and avoiding serious operational disruptions. Many new agencies are caught off guard by how GSA requirements impact not just compliance but also staffing, service delivery, and expansion plans.
At The Home Health Consultant, we’ve helped countless new agencies obtain the largest possible GSA. In this article, we’ll break down:
- what GSA is
- why understanding your GSA is essential for your agency
- recent changes to the way California regulatory bodies are reviewing GSAs
By the end of this article, you’ll be an expert in understanding GSAs, and understand the dos and don’ts for this regulation in 2025 and beyond.
What is a GSA?
GSA stands for Geographical Service Area—the defined region where your agency is allowed to provide services to patients. This area is reviewed and approved by the California Department of Public Health (CDPH) and, subsequently, by your accrediting organization (AO).
If deemed too expansive or impractical, parts of your proposed GSA may be excluded. However, no penalties are applied for these adjustments.
So, when applying for a new or your first GSA, reach for the stars. It’s always better to aim for a higher GSA and get areas removed, than limit your agency with a smaller GSA.
An agency’s GSA is reevaluated every time it undergoes a significant change, such as moving its location. If your GSA isn’t approved by:
- CDPH
- your accrediting organization (AO),
- and the Centers for Medicare & Medicaid Services (CMS)
…your agency will not be permitted to operate or deliver care in those areas. This makes maintaining an accurate and compliant GSA crucial.
How Does GSA Impact Staffing, Referrals, and Compliance?
While first and foremost your GSA determines the area you can serve patients in, there are other aspects to consider as well. These include:
- Staffing Compliance: Your staff must be able to reach patients within the approved GSA in a timely manner to provide quality care.
- Referrals: An appropriate GSA ensures your agency can confidently accept referrals within your service range. To read more about referrals, check out our article Laws & Regulations Around Marketing Your Home Health or Hospice Agency.
- Regulatory Compliance: Serving patients outside your GSA can lead to compliance violations. Although we have not seen consequences enforced for serving patients outside of your GSA, it’s always best to remain totally compliant with state and federal regulations.
Why are GSAs Required for Home Health & Hospice?
GSAs are a foundational part of opening a home health or hospice agency. They help ensure agencies are transparent about their coverage areas and maintain feasible operations.
While Medicare doesn’t impose stringent GSA rules nationwide, California’s process is more rigorous. This localized approach ensures agencies can realistically meet patient needs and maintain compliance.
For California agencies:
- Home Health: GSAs must fall within a four-hour driving radius from the agency’s base.
- Hospice: The radius is reduced to two hours, considering the urgent nature of end-of-life care.
- Both: Neither hospice nor home health GSAs can cross state lines. Meaning if your agency is in California, you must only include California zip codes in your GSA
How Do You Determine and Maintain the Right GSA for Your Agency?
Your agency’s location is one of the many things you have to report to regulatory bodies. When determining your GSA, consider the following:
- Initial Licensing: New agencies must propose a GSA during the initial licensing process. This is often calculated using zip codes and may require adjustments based on feedback from CDPH and your AO.
- Changes in Location: Agencies licensed before 2020 may have larger GSAs due to previous leniencies. Recent regulatory changes have significantly restricted GSA sizes.
- Ownership Transfers: Purchasing an agency does not guarantee its existing GSA will remain intact. Moving the agency location almost always triggers a reassessment of the GSA, which could result in reductions.
- Time of Day When Calculating Drive Time: GSA determinations can be based on drive times calculated during low-traffic periods. This has the potential to maximize your coverage area. While some analysts may want to adjust for peak traffic conditions, others may keep the original assessment unchanged.
What Does Applying for your GSA Actually Look Like?
Your GSA is reported to the California Department of Public Health (CDPH), your accrediting organization (AO), and your Medicare Administrative Contractor (MAC).
To complete the application, you must gather and submit the following:
- List of ZIP codes, cities, and counties in your proposed service area.
- A detailed map with your coverage area clearly drawn.
- Specific ZIP codes—every single ZIP code within your intended coverage area must be listed explicitly.
See the chart below for an example of how to display and submit the zip codes for your proposed GSA.
Pro Tip: Print the final approved ZIP code list and place it at the intake desk for quick reference. A digital version is acceptable, but a physical copy can be more convenient when trying to determine if you can accept a patient.
The map below shows an example what an approved California home health or hospice agency GSA can look like (as of February 6th, 2025). However, GSA approval can be subjective. Different analysts have different approaches to reviewing and approving GSAs.
Need help finding ZIP codes or a state map? Click below to get access to free resources and help you determine your GSA.
Pro Tip: Don't forget! Once approved, your coverage area map must be displayed on a visible wall in your agency.
Helpful Tips for Navigating GSA Changes in 2025 & Beyond
The way regulations are enforced, particularly but not exclusively with GSA, is always evolving. Technological advances, specifically the introduction of EMR’s (Electronic Medical Record Systems) has led to a significant increase in GSA approval sizes over the past two decades.
Previously CDPH approved a maximum of a 50 mile radius for any agency, to allow for timely submission of clinical notes. Now, the limits have increased to 2-4 hours driving time for home health & hospice respectively. Staying informed about these shifts can be critical to your agency's success and competitive advantage. If your agency is older and still is limited to 50 miles, it may be time to update.
At The Home Health Consultant, we’ve seen CDPH be more strict about GSAs in recent months. This often results in smaller GSAs being approved than what we’ve seen before. With this in mind, here are a few things to keep in mind when it comes to how this change could affect your agency:
- Grandfathered Agencies: If your agency was licensed under older, less restrictive guidelines, be cautious about relocating, as this could jeopardize your existing GSA.
- Plan Ahead: Before buying an agency, thoroughly evaluate its GSA status and any potential changes that could arise from a move or ownership transfer.
The best way to stay up to date on any changes in enforcement is by working with a consultant. Consultants see these forms, their approvals, and their denials on a regular basis. Their firsthand experience can help your agency navigate the process with confidence.
How Can Your Agency Stay GSA Compliant?
Navigating GSA regulations can be overwhelming for home health and hospice agencies. However, with over two decades of experience, The Home Health Consultant has helped countless agencies overcome this challenge—from seamless application submissions to comprehensive compliance reviews.
It’s time to take control of your agency’s future. Dive into our expert resources to stay informed about the latest industry updates and maintain your agency’s success. If you're curious about other mandatory submissions, check out our article on ALIRTS.
*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.
