How to Get Medicare Certified for Home Health or Hospice: What CMS Surveyors Look For

Becoming Medicare-certified is the most significant milestone for any home health or hospice agency. Without Medicare certification, an agency cannot bill Medicare, cannot operate at scale, and cannot be competitive in the healthcare market. But achieving certification requires far more than submitting an application—it requires deep compliance with the Medicare Conditions of Participation (CoPs) and surviving an unannounced CMS survey conducted by a state agency or accrediting body.

This comprehensive guide explains exactly what CMS surveyors look for, how to prepare, where most agencies fail, and how to navigate the certification process successfully. It applies to both home health (42 CFR §484) and hospice (42 CFR §418) agencies.

1. Understanding Medicare Certification for Home Health & Hospice

To become Medicare-certified, your agency must complete the following steps:

1. Obtain appropriate state licensure

2. Submit Medicare enrollment forms (CMS-855A)

3. Prepare for and undergo a CMS certification survey

4. Demonstrate full compliance with Medicare Conditions of Participation

5. Receive approval and be added to PECOS & CMS billing system

The certification survey is the most critical part of the process. CMS surveyors evaluate:

• Patient care delivery

• Agency governance

• Clinical documentation

• Personnel competency

• Emergency preparedness

• Quality Assurance & Performance Improvement (QAPI)

• Compliance with state and federal laws

Surveyors follow the CMS State Operations Manual (SOM) and evaluate for deficiencies, which must be corrected before certification.

2. What CMS Surveyors Look For: The Core Areas of Focus

CMS surveyors examine whether your agency meets all Medicare CoPs, which define how agencies must operate. Below are the key areas surveyors focus on during home health and hospice certification surveys.

A. Governance & Administrative Structure

Surveyors evaluate whether the agency is well-structured, compliant, and properly managed. They will check for:

• Governing body structure and meeting minutes

• Policies and procedures that match actual operations

• Job descriptions that match CoP requirements

• Personnel files with complete onboarding documentation

• Credentialing, licensure, and competency validations

• Organizational chart that reflects lines of authority

Surveyors often cite agencies for:
❌ Missing signed job descriptions
❌ Gaps in personnel files
❌ Missing administrator / clinical director credentials
❌ Policies not reflecting actual practice

B. Patient Rights & Patient-Informed Services

CMS prioritizes patient rights heavily. Surveyors will interview patients and families to confirm the agency:

• Provided written patient rights

• Explained the rights in understandable language

• Obtained signed consent for care

• Provided HIPAA notice of privacy practices

• Offered a process for complaints and grievances

For hospice, surveyors also check for:

• Election of benefit forms

• Revocation and discharge notices

• Advance directive documentation

C. Clinical Documentation & Care Planning

One of the top areas of deficiency.

Home Health Requirements

Surveyors verify that:

• OASIS assessments were completed correctly

• A comprehensive assessment was completed within 5 days

• The POC matches clinical needs and MD orders

• Visits were completed as ordered

• Skilled need is clearly documented

• Supervisory visits were performed

Hospice Requirements

Surveyors check for:

• RN initial assessment within 48 hours

• Comprehensive assessment within 5 days

• Interdisciplinary Group (IDG) meetings every 15 days

• Plan of care updated with measurable goals

• Medication profiles updated in real time

• Documentation supporting terminal prognosis

Deficiencies here often lead to immediate jeopardy because they directly impact patient care.

D. Coordination with Physicians

For home health:

• Signed orders

• Face-to-Face encounter documentation

• POC approval and updates

For hospice:

• Physician narrative for terminal illness

• Recertification every 90/60 days

• Physician involvement in IDG

• Medication review and oversight

Surveyors frequently cite:
❌ Missing or unsigned MD orders
❌ Inadequate CTI (Certification of Terminal Illness) for hospice
❌ Poor documentation of physician communication

E. Skilled Services & Visit Notes

Surveyors review:

• RN, LVN/LPN, PT, OT, ST, MSW, HHA visit notes

• Missed-visit documentation

• Whether the care provided matches the plan of care

• Frequency and duration expectations

• Documentation of skilled interventions

They look for clinical justification—not copy-paste notes or vague language.

F. Emergency Preparedness (Appendix Z)

This is one of the most frequently cited areas.

Surveyors evaluate:

• All-hazards risk assessment

• Emergency preparedness plan

• Communication plan

• Training and testing documentation

• Tabletop and full-scale exercises

• Staff education and participation records

CMS requires documentation of two emergency drills each year, and surveyors will ask staff detailed questions about their roles.

G. Quality Assurance & Performance Improvement (QAPI)

CMS requires a data-driven quality program. Surveyors check whether the agency:

• Has a written QAPI program

• Conducts quarterly QAPI meetings

• Tracks performance indicators

• Monitors adverse events, infections, and complaints

• Implements performance improvement projects (PIPs)

• Shows measurable improvement over time

Surveyors expect real data, not generic templates.

H. Infection Control Program

Surveyors review your infection control program for:

• Policies aligned with CDC best practices

• PPE usage and training

• Exposure control plans

• Reporting systems for infections

• Hand hygiene compliance

• Staff competency for infection control

For home health, they especially review caregiver education on infection prevention in the home setting.

3. What Happens During a CMS Survey

A Medicare certification survey includes:

Stage 1: Entrance Conference

Surveyors:

• Meet with your administrator

• Request key documents

• Outline the survey process

• Begin policy and record review

Stage 2: Record Review

Surveyors select multiple patient charts. They evaluate:

• Assessments

• Plans of care

• Orders

• Communication notes

• Visit documentation

• Coordination

They compare documentation with actual care delivered.

Stage 3: Home or Facility Visits

Surveyors will go into the field to visit patients. They observe:

• Quality of care

• Accuracy of documentation

• Whether visit frequency matches the care plan

Stage 4: Staff & Patient Interviews

Surveyors interview:

• Administrators

• Clinical director

• RNs / LVNs / CNAs

• Therapists

• Medical social workers

• Patients and caregivers

They check for:

• Staff competency

• Knowledge of emergency preparedness

• Understanding of patient rights

• Ability to describe processes

Stage 5: Exit Conference & Survey Results

Surveyors present deficiencies (if any) and explain:

• Condition-level findings

• Standard-level findings

• Required corrective actions

• Timelines for Plan of Correction (POC)

Agencies must submit a POC in writing, detailing how each deficiency will be corrected.

4. Common Deficiencies Home Health & Hospice Agencies Receive

CMS publishes the top deficiencies annually. The most common include:

Home Health

• G570 (Skilled services not provided as ordered)

• G320 (Care planning deficiencies)

• G170 (Patient rights not properly implemented)

• G800 (OASIS not transmitted or inaccurate)

• G1000 (Infection control program deficiencies)

Hospice

• L557 (Inadequate interdisciplinary group services)

• L541 (Assessment documentation incomplete)

• L630 (Plan of care not individualized)

• L623 (Medication management deficiencies)

• L715 (Emergency preparedness deficiencies)

5. Tips for Passing Your Medicare Certification Survey

Here is what the most successful agencies do:

A. Conduct a Mock Survey Before the Real One

A full mock survey identifies:

• Policy gaps

• Documentation weaknesses

• Staff training needs

• Noncompliant processes

Mock surveys should mirror the real CMS survey.

B. Ensure Documentation Matches Real Practice

CMS is strict about documentation accuracy. Every document must:

• Be complete

• Be timely

• Be consistent across records

• Reflect skilled need (home health)

• Reflect terminal prognosis (hospice)

C. Train Your Staff Regularly

Surveyors expect:

• Annual competencies

• Skills checklists

• Emergency preparedness training

• Documentation education

• Orientation and ongoing training

D. Keep QAPI Active — Not Just on Paper

CMS expects QAPI to demonstrate:

• Measurable performance improvement

• Routine evaluation of outcomes

• Agency-wide participation

E. Have Policies That You Actually Follow

Surveyors immediately cite agencies whose actions contradict their own policies.

F. Be Organized — First Impressions Matter

Have the following ready:

• Personnel files

• Training documentation

• Policy manual

• QAPI binder

• Emergency preparedness binder

• Patient charts

• Admission packets

6. Timeline to Become Medicare Certified

Although timeframes may vary, the average timeline is:

1. Licensing – 2–3 months

2. Readiness preparation – 1–3 months

3. Survey wait time – depends on state & CMS workload

4. Survey – 2–5 days

5. Plan of Correction – 10–30 days

6. CMS certification decision – 30–90 days

Total average time: 6–12 months.

7. Final Thoughts: Achieving Medicare Certification Successfully

Becoming Medicare certified for home health or hospice is challenging, but with strong compliance systems, thorough preparation, and proper documentation, agencies can pass their CMS survey successfully.

The key is to understand what CMS surveyors look for, ensure all operational systems are compliant, and conduct regular mock surveys to identify gaps.

Need Expert Help? SummitRidge Consulting Can Assist You

If you want professional support with:

• Medicare certification

• CMS 855A applications

• Policies & procedures

• Mock surveys

• Clinical documentation review

• QAPI program development

• Staff training

• Survey readiness and deficiency correction

SummitRidge Consulting offers complete end-to-end consulting and management solutions to help home health and hospice agencies achieve full compliance and pass their Medicare surveys with confidence.