Home health and hospice agencies face unique challenges in staying compliant with Medicare and state regulations. Surveys are not just routine inspections. They are critical evaluations that decide whether your agency can keep operating and serving patients. Depending on your deficiencies, failing a survey can potentially lead to agency closure.
At The Home Health Consultant, we’ve been guiding agencies through surveys and communicating with surveyors for over 20 years. Over that time, we haven’t just mastered teaching agencies how to prepare for surveys—we’ve also gained insight into how surveyors approach your survey.
This guide highlights key areas surveyors focus on. It offers strategies to keep your agency ready for surveys. Whether you’re new to surveys or experienced, this guide is for you.
By the end of this article, you’ll have clear steps to stay compliant and prepared. With so much at stake, it’s a must-read for anyone focused on passing their surveys and maintaining high standards.
What is a Survey?
Surveys are inspections designed to ensure compliance with the Medicare Conditions of Participation (CoPs) and other regulations. They’re a way to protect patient safety and improve care outcomes in home health (HH) and hospice (HSP) settings. These assessments are critical for agencies to maintain Medicare certification and funding.
What is a Surveyor?
Surveyors are trained professionals who assess agencies against federal and state regulations. Surveyors often have clinical or administrative healthcare backgrounds. They review documentation, interview staff and patients, and observe operations to evaluate compliance.
Who Do Home Health or Hospice Surveyors Work For?
To better understand what surveyors and accreditors are looking for and why, it’s important to understand who they report to.
Surveyors work for:
- Centers for Medicare & Medicaid Services (CMS): CMS oversees federal surveys. Federal surveyors may conduct validation surveys or investigate immediate jeopardy situations.
- State Survey Agencies (SSAs): SSAs operate under CMS. They are responsible for initial and recertification surveys, as well as investigating complaints.
- Accreditors: Accreditors are independent organizations that conduct accreditation surveys for agencies seeking deemed status under CMS guidelines. The three national accreditors are:
By understanding who your surveyor is reporting to, you can gain a better understanding of what to expect in your survey.
What Role Do Medicare Conditions of Participation (CoPs) Play in Your Survey?
CoPs are regulatory requirements that all HH and HSP agencies must meet to be able to bill Medicare. They include standards for patient care, quality improvement, infection control, and administrative operations. Examples include:
- HH CoPs: Focus on the delivery of skilled nursing, therapy services, and care planning.
- HSP CoPs: Emphasize interdisciplinary care, symptom management, and family support services.
CoPs are the regulations that surveyors are looking to make sure your agency is following the law during a survey.
How Do Surveyors Prepare for a Survey?
While your agency is busy preparing for your survey, the surveyors also have preparation steps they take.
- Pre-Survey Preparation
- Historical Review: Examining previous survey reports, complaint investigations, and CMS-2567 (plan of corrections) forms to identify areas of concern.
- Performance Data Analysis: Reviewing quality metrics, such as OASIS data for HH agencies or hospice quality reporting measures.
- Agency Background: Researching agency size, services offered, and patient census to tailor the survey focus.
- Survey Team Assembly
- Teams often include RNs and other specialists depending on the scope of the survey. For hospice agencies, surveyors may include professionals with expertise in end-of-life care.
- Typically there will only be one surveyor at your survey, unless the agency has a large census or the surveyor is training someone.
- Survey Strategy Development
- Identifying potential high-risk areas to prioritize during the onsite visit, such as infection control protocols or patient care planning.
What Do Home Health and Hospice Surveyors Look For?
Once the surveyor arrives at your office, they could look at anything and everything depending on your type of survey. But these are the main areas they check to make sure you are compliant with Medicare CoPs.
1. Patient Care Delivery
Surveyors assess whether care is delivered effectively, safely, and in accordance with individualized care plans:
- HH Agencies:
- Evidence of skilled nursing and therapy interventions.
- Compliance with care coordination and timely delivery of services.
- HSP Agencies:
- Effectiveness of pain and symptom management.
- Quality of interdisciplinary team (IDT) collaboration.
2. Documentation and Records
Surveyors meticulously review:
- Care Plans: For accuracy, timeliness, and evidence of patient involvement.
- Clinical Records: To ensure compliance with CoPs and adherence to professional standards.
- Incident Reports: Documentation of adverse events, follow-up actions, and preventive measures.
3. Staffing and Qualifications
Surveyors verify that staff meet licensure and qualification requirements:
- Home Health: Includes compliance and availability for DPCS, clinical supervisors and all discipline field staff, especially home health aides.
- Hospice: Focuses on medical director involvement, volunteer qualifications, and IDT composition.
There are times where mistakes can fall through the cracks, only to be uncovered during your survey. Double check to make sure all of your staff are qualified and meet the requirements for their positions.
4. Infection Control Practices
- HH Agencies: Surveyors evaluate infection prevention and control measures during home visits, including PPE usage and hand hygiene.
- HSP Agencies: Focus on education programs for staff and families on infection prevention, especially for patients in shared living environments.
5. Emergency Preparedness
Surveyors ensure agencies are equipped to respond to emergencies:
- Plans: Comprehensive emergency preparedness plans that meet federal and state requirements.
- Training Records: Evidence of staff training in disaster response.
- Drills: Documentation of conducted emergency drills.
6. Physical Environment
Surveyors inspect facilities and home environments for safety and compliance:
- Equipment Maintenance: Regular checks on medical devices and safe use of equipment as required by manufacturer guidelines.
- HSP Facilities: Evaluations of inpatient units for hospice care.
- Confidentiality: Assessment of HIPAA and other privacy practices in the office setting.
- Home Safety: Analysis of the agency’s maintenance of the patient’s home environment from the perspective of patient safety.
7. Patient Rights
Agencies must demonstrate that they uphold patient rights, including:
- Providing written notice of rights.
- Ensuring informed consent for treatments.
- Safeguarding patient privacy and dignity.
8. QAPI
Surveyors evaluate your QAPI program to ensure compliance with regulations and your agency's own policies.
- Topic Selection: Topics should focus on high-risk or high-utilization areas, backed by standardized data sources and rationale.
- Execution: Surveyors check if you are effectively executing your QAPI program as outlined in your policies.
- Policies and Procedures: Evidence that your QAPI program reflects and is guided by comprehensive, original policies designed for home health and hospice operations.
- Documentation: Ability to demonstrate how identified issues are monitored, analyzed, and acted upon, ensuring continuous quality improvement.
Why Is It Crucial to Understand What Surveyors Look For?
Proactively addressing survey focus areas can:
- Minimize the risk of deficiencies and penalties.
- Protect Medicare certification and funding.
- Enhance the quality of care, boosting patient satisfaction and agency reputation.
What Can You Do to Stay Survey Ready?
To be the most successful in your home health or hospice survey, we recommend practicing survey readiness over last minute preparation. Here’s a list of ways your agency can stay survey ready:
- Develop a Culture of Readiness: Implement ongoing compliance training and QAPI programs to address systemic weaknesses.
- Perform Internal Audits: Regularly review documentation, conduct mock surveys, and address identified gaps.
- Engage Experts: Hire consultants with expertise in survey readiness to guide your agency through preparation and address complex compliance challenges.
- Invest in Staff Training: Ensure staff understands survey protocols and can respond confidently to surveyor questions.
- Understand that Compliance Takes Time: Be patient with compliance implementation; it can require an overhaul of your operations and mindset. If you’re prepping for survey, allow about one year to get all processes evaluated, updated and implemented if needed.
By understanding what surveyors look for and proactively addressing these areas, your agency can successfully navigate surveys and continue to provide exceptional patient care.
Are you Prepared for Your Next Home Health or Hospice Survey?
Navigating home health and hospice surveys requires preparation and a commitment to excellence. Understanding what surveyors look for and proactively addressing high-risk areas can help your agency secure Medicare certification. It also protects funding and ensures you deliver exceptional care.
Ready to dive deeper? If you're new to surveys and need a clearer understanding of the types, check out our article on the six different kinds of surveys for home health and hospice agencies in California.
If you're already familiar with the basics but need help prepping for your next survey, read our guide on ‘How to Prep for Your First 30 Minutes of a Survey’. No matter your experience level, we've got the resources to help you navigate this challenging regulatory landscape.
*This article was written in consultation with Mariam Treystman.
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