Accreditation vs. CMS Survey for Home Health: What’s the Difference?

For home health agencies, compliance is not optional—it’s the foundation on which patient safety, reimbursement, and agency survival all depend. Whether you are a new agency preparing for certification or an established provider maintaining compliance, it’s essential to understand the difference between private accreditation and the federal CMS survey process. Although both approaches evaluate your organization’s readiness to deliver safe, high-quality home health services, their structure, requirements, timelines, and long-term implications vary significantly.

This detailed guide breaks down the distinctions between Accreditation Surveys and CMS State Surveys, with emphasis on the Home Health Medicare Conditions of Participation (CoPs). You’ll learn how each process works, what surveyors examine, how agencies should prepare, and which pathway may be best for your organization.

1. Overview: Why Surveys Matter in Home Health

The Centers for Medicare & Medicaid Services (CMS) requires all Medicare-certified home health agencies to comply with the Medicare Conditions of Participation (42 CFR §484). The purpose of surveys—whether performed by CMS or an accrediting organization—is to verify:

• Compliance with CoPs

• Patient safety and quality of care

• Proper clinical documentation

• Safe and effective operations

• Competent and trained staff

• Readiness to bill Medicare and serve beneficiaries

Failure to comply can lead to deficiencies, plans of correction, payment suspensions, rapid recertification interventions, or even termination from the Medicare program.

There are two primary pathways for demonstrating compliance:

1. CMS State Survey

2. Private Accreditation Survey through organizations like ACHC, CHAP, or Joint Commission

Understanding their differences is critical for agency success.

2. CMS State Survey (Federal Survey): What It Is and How It Works

A CMS State Survey is conducted by surveyors from the state agency (such as the Department of Public Health). It is a government-administered inspection with strict federal oversight.

What Triggers a CMS Survey?

• Initial Medicare certification (after receiving a state license, if applicable)

• Re-certification surveys every 2–3 years

• Complaint investigations

• Follow-up visits to verify correction of deficiencies

• Targeted reviews due to data outliers in OASIS, quality indicators, or CAHPS

Survey Approach

CMS uses the Home Health Survey Protocols and the State Operations Manual (SOM) to guide surveyors. These include:

• Clinical record reviews

• Home visits with patients (ride-alongs)

• Staff competency evaluations

• Interviews with patients, caregivers, & staff

• Policy and procedure review

• Observation of care delivery

Surveyors operate under federal authority. They cannot provide consultation, hints, or improvement suggestions during or after the survey.

Deficiency Levels

Findings are categorized from least to most severe:

• Standard-Level Deficiencies

• Condition-Level Deficiencies (serious noncompliance with CoPs)

• Immediate Jeopardy (IJ) (imminent threat to patient safety)

Condition-level and IJ findings can jeopardize certification, billing ability, and agency operations.

Pros of CMS Surveys

• Free (no accreditation fee)

• Direct path to Medicare certification

• High level of regulatory credibility

Cons of CMS Surveys

• Long and unpredictable wait times for initial certification

• More punitive in nature

• No surveyor guidance or education

• Surveys may be more intense or less flexible

3. Accreditation Survey: What It Is

Private accrediting bodies—ACHC, CHAP, and Joint Commission—are CMS-approved organizations that can grant “deemed status.”

When an agency chooses accreditation, the accrediting body performs the survey, and CMS accepts the results in place of a state survey.

Why Agencies Choose Accreditation

Accreditation is often chosen to:

• Avoid long state wait times for initial surveys

• Access surveyors who provide education and best-practice guidance

• Enhance agency credibility and marketability

• Receive structured support throughout the compliance process

• Demonstrate commitment to quality to referral partners

Survey Approach

Accreditation surveys are highly comprehensive and equally aligned with the Medicare CoPs—but with a more collaborative tone.

Survey activities include:

• Record audits

• Home visits

• Interviews

• Policy review

• Competency assessments

• Organizational leadership evaluation

• Performance improvement review

• Emergency preparedness evaluation

Accreditation surveyors may point out areas for improvement, provide education, and help agencies understand the intent of the CoPs.

Pros of Accreditation

• Faster path to Medicare certification

• Collaborative, educational experience

• Strong industry credibility

• Marketing advantage (Accredited = High quality)

• Access to resources, templates, and ongoing support

Cons of Accreditation

• Annual or triennial fees

• Additional standards beyond CMS

• More preparation required

4. Accreditation vs. CMS Survey: Key Differences

A. Purpose & Authority

FactorCMS State SurveyAccreditation SurveyAuthorityFederal government (CMS)Private CMS-approved organizationPurposeEnforcementQuality improvement + complianceToneRegulatoryEducational

B. Wait Time

CMS State Survey:

• Can take months or years depending on state backlog.

• Significant delays in high-volume states.

Accreditation Survey:

• Scheduled promptly after application.

• Predictable timelines—critical for start-ups.

C. Cost

CMS Survey: Free
Accreditation: Paid (varies by accrediting body)

However, many agencies view accreditation fees as an investment in smoother operations and faster certification.

D. Surveyor Interaction

CMS:

• Surveyors cannot offer guidance.

• No consultation or recommendations.

• More “black and white” interpretation.

Accreditation:

• Surveyors can educate and explain standards.

• Provide clarification and best practices.

• Much more collaborative approach.

E. Standards Reviewed

Both evaluate the Medicare CoPs, but accreditation bodies often include additional quality standards, such as:

• Leadership and governance

• Clinical excellence benchmarks

• Performance improvement beyond CoP minimums

• More rigorous infection control and safety requirements

F. Frequency of Surveys

CMS State Survey:

• Every 2–3 years

• Plus complaints, targeted audits, and follow-ups

Accreditation:

• Every 3 years (ACHC, CHAP, Joint Commission)

• Some require annual updates or self-assessments

5. Preparing for Either Survey: What Agencies Must Have Ready

Regardless of survey pathway, home health agencies must demonstrate full compliance with the CoPs. Key areas include:

1. Clinical Documentation

• Comprehensive assessments (§484.55)

• Plan of Care accuracy (§484.60)

• Skilled need justification

• Timeliness and coordination of services

• Homebound status documentation

• Visit notes matching ordered services

• OASIS accuracy

2. Policies & Procedures

Policies must reflect CoPs and represent actual practice, including:

• Admission criteria

• Plan of care development

• Infection prevention and control

• Patient rights & grievances

• Medication management

• Emergency preparedness

• Personnel files and competency

3. Personnel Requirements

• RN and therapist competencies

• Background checks

• Orientation documentation

• Annual evaluations

• Supervision of aides (§484.80)

4. Quality Assurance & Performance Improvement (QAPI) (§484.65)

Surveyors evaluate:

• Performance data

• QAPI meetings

• Projects showing measurable improvement

• Clinical record review systems

5. Emergency Preparedness (Appendix Z)

Must include:

• Risk assessment (all-hazards)

• Policies and procedures

• Communication plan

• Training and testing exercises

6. Which Should You Choose? Accreditation or CMS?

Best Choice for New Agencies

Accreditation — faster, smoother, more predictable.

Best Choice for Agencies on a Tight Budget

CMS State Survey — free but unpredictable.

Best Choice for Agencies Seeking Market Advantage

Accreditation — higher perceived value by hospitals and referral sources.

Best Choice for Agencies Needing Stronger Internal Systems

Accreditation — offers ongoing resources, structure, and education.

7. Final Thoughts

Both accreditation surveys and CMS state surveys serve the same purpose: to ensure home health agencies meet the Medicare Conditions of Participation and provide safe, high-quality care. But the pathway an agency chooses impacts not only the timeline of certification, but also the level of support, education, and operational structure they receive during the process.

For agencies seeking consistent support, faster timelines, and a more guided experience, accreditation is often the top choice. For agencies comfortable navigating compliance independently or working with consultants to fill the gaps, a CMS state survey may be sufficient.

Regardless of which path you select, success depends on preparation, documentation accuracy, and strong operational systems.

Need Help Preparing for Accreditation or CMS Survey?

SummitRidge Consulting specializes in compliance, Medicare CoPs readiness, documentation review, mock surveys, and full operational support for home health agencies nationwide.

Whether you're seeking initial certification or preparing for re-accreditation, SummitRidge ensures your agency is ready—clinically, operationally, and administratively.