Medicare Hospice Surveys Types

Medicare-certified hospice agencies are required to meet the Medicare Conditions of Participation (CoPs) to ensure patient safety, quality of care, and organizational accountability. To verify compliance, the Centers for Medicare & Medicaid Services (CMS) and State Survey Agencies conduct different types of hospice surveys—each with unique triggers, timelines, processes, and consequences. Understanding these survey types is critical for maintaining compliance, avoiding deficiencies, and safeguarding your hospice’s Medicare certification.

This comprehensive guide outlines the four major Medicare hospice survey types, what triggers them, and how agencies can maintain continuous readiness. This article is designed to align with CMS federal regulations at 42 CFR Part 418 and is fully optimized for searchers seeking hospice survey guidance, home health regulatory information, and Medicare compliance resources.

1. Standard (Routine) Hospice Surveys

Purpose

A standard survey is the most common type of Medicare hospice survey. It evaluates whether a hospice agency is compliant with the full Medicare Conditions of Participation, including patient rights, interdisciplinary group (IDG) processes, care planning, QAPI, infection control, emergency preparedness, documentation, and administrative readiness.

Frequency

CMS requires that every Medicare-certified hospice provider undergo a standard survey no less frequently than every 36 months. States may conduct them more frequently depending on resources and risk indicators.

What Surveyors Evaluate

Surveyors conduct a comprehensive assessment that includes:

Patient-Centered Care Compliance

• Eligibility documentation (terminal prognosis of 6 months or less)

• Certification of terminal illness (CTI) and face-to-face visits

• Up-to-date plan of care reflecting patient needs, goals, and preferences

• Coordination of care across the interdisciplinary team

Clinical Record Review

Surveyors review a random sample of hospice patients and ensure:

• Accurate visit documentation

• Medication reconciliation

• Symptom management interventions

• Timely updates to the comprehensive assessment

• Proper Hospice Item Set (HIS) documentation or HOPE-relevant processes

Home Visits

Surveyors may accompany clinicians to patient homes to observe:

• IDG communication in practice

• Appropriateness of visits

• Safety practices

• Interactions with families and caregivers

Administrative Compliance

Administrative oversight is also evaluated:

• Governing body minutes

• Quality Assessment and Performance Improvement (QAPI) program

• Contracted services oversight

• Emergency preparedness drills

• Personnel files, competencies, licensing, and training documentation

Outcome

A standard survey may result in:

• No deficiencies

• Standard-level deficiencies

• Condition-level deficiencies

• Immediate jeopardy findings

Condition-level or IJ findings can lead to termination from Medicare if not corrected within mandated timeframes.

2. Extended (Follow-Up) Surveys

Purpose

Extended surveys are conducted after deficiencies are identified during a standard survey—especially when serious compliance concerns are present.

Extended surveys determine:

• If deficiencies have been corrected

• Whether systemic issues still exist

• If new deficiencies have emerged in related services

Triggers

Extended surveys typically occur when:

• A standard survey reveals condition-level deficiencies

• Immediate jeopardy was cited

• The State Agency determines the need for a more in-depth review

• CMS requests additional oversight

Scope

Extended surveys generally include:

• Areas related to previously cited deficiencies

• Oversight of administrative leadership

• QAPI validation

• Training and competency assessments

• Review of policy changes implemented after the initial survey

Outcome

If the extended survey shows adequate correction, CMS closes the enforcement case. If not, the hospice may face:

• Civil monetary penalties

• Directed plans of correction

• Temporary management

• Termination of Medicare certification

For this reason, agencies must maintain robust, documented corrective actions that demonstrate sustainable change.

3. Complaint Surveys

Purpose

Complaint surveys involve investigation of allegations made by patients, families, staff, competitors, or community members. CMS requires prompt responses to complaints involving patient safety or rights violations.

Common Complaint Allegations

• Poor symptom management or medication errors

• Unsafe clinical practices

• Staff misconduct or neglect

• Lack of communication with families

• Delayed or missed visits

• Failure of interdisciplinary team coordination

• Billing or financial concerns

• Violations of patient rights and dignity

Process

Complaint surveys are unannounced and often occur within hours to days of a filed allegation, depending on severity.

Surveyors may:

• Contact the complainant

• Conduct home visits

• Review patient records

• Interview staff

• Evaluate policies and procedures

Priority Levels

CMS categorizes complaint investigations based on risk:

Immediate Jeopardy Risk

Responded to within 24 hours
Examples:

• Life-threatening medication errors

• Abuse allegations

• Critical neglect

High Priority

Responded to within 10 days
Examples:

• Symptom control failures

• Pattern of missed visits

Medium/Low Priority

May be grouped with a standard survey if not urgent.

Outcome

Unresolved complaints can lead to:

• Deficiencies

• Condition-level citations

• Enforcement actions

• Increased frequency of future surveys

Hospice agencies should maintain a strong complaint management program, including timely grievance resolution and ongoing staff training.

4. Validation Surveys (Federal or Accrediting Organization Oversight)

Purpose

Validation surveys ensure that standards applied by accrediting bodies such as CHAP, ACHC, or Joint Commission align with CMS requirements.

They occur after an accrediting organization (AO) completes a survey.

Types of Validation Surveys

a. Direct Observational Validation

CMS surveyors accompany the AO survey team simultaneously.

b. Comparative Validation

CMS conducts its own survey shortly after the AO survey—usually within 60 days.

The goal is to determine whether the AO’s survey findings match CMS’s evaluation.

Triggers

Validation surveys may occur:

• Randomly as part of CMS’s quality oversight schedule

• When CMS has concerns about AO performance

• If a complaint is filed shortly after AO accreditation

Possible Outcomes

• No additional findings

• Identification of deficiencies missed by the AO

• AO oversight review

• Directed corrective actions

Validation surveys ensure that Medicare-certified agencies maintain consistent quality standards regardless of who performs the survey.

How Hospice Agencies Can Maintain Continuous Survey Readiness

Whether facing a standard survey or a complaint investigation, hospices must maintain daily readiness. Best practices include:

1. Keep Documentation Survey-Ready at All Times

• Complete clinical notes within 24 hours

• Ensure CTI and face-to-face visits are timely and compliant

• Maintain complete, updated plans of care

Surveyors often cite agencies for incomplete documentation, making daily discipline essential.

2. Conduct Regular Chart Audits

Implement structured monthly audits for:

• Eligibility

• Visit frequency

• Medication reconciliation

• Symptom management

3. Strengthen QAPI Processes

A strong QAPI program:

• Demonstrates ongoing improvement

• Tracks adverse events

• Ensures systemic compliance

Surveyors will expect measurable, data-driven outcomes.

4. Maintain Strong Emergency Preparedness Compliance

Review and update:

• Hazard vulnerability analysis

• Full-scale and tabletop exercises

• Staff emergency training

5. Train Staff Continuously

Surveyors interview staff to evaluate knowledge of:

• Patient rights

• Emergency preparedness

• Abuse prevention

• Infection control

• Reporting requirements

Every employee—from volunteers to RNs—must be confident in their role.

6. Conduct Mock Surveys

Mock surveys help agencies:

• Identify gaps

• Correct risks early

• Prepare staff for surveyor questions

Mock surveys should include home visits, administrative review, and clinical record audits.

Why Understanding Medicare Hospice Survey Types Matters

Survey readiness is not optional—it's essential for:

• Maintaining Medicare certification

• Protecting your hospice license

• Ensuring patient safety and regulatory compliance

• Avoiding costly deficiencies

• Preventing conditions that jeopardize your agency

Hospice providers that understand survey types and expectations are better positioned to deliver high-quality, compliant care.

Need Expert Support?

For agencies seeking professional support in:

• Survey preparation

• Mock surveys

• QAPI development

• Documentation improvement

• Corrective action writing

• Hospice startup or management

SummitRidge Consulting provides comprehensive consulting and regulatory compliance solutions for hospice and home health organizations.