CMS Lifts Home Health Moratoria in FL, TX, MI & IL

According to the Centers for Medicare & Medicaid Services (CMS), “As of January 30, 2019, there are no active Medicare Provider Enrollment Moratoria in any State or U.S. territories.”  CMS announced Wednesday that the provider enrollment moratoria on home health agencies in Illinois, Michigan, Texas, and Florida have expired. The notice from CMS can be read here.

ACHC is able to expeditiously conduct an Initial Medicare Certification Survey for home health agencies (HHAs) in these states. An organization may apply for accreditation if the following eligibility requirements are met.

The organization must:

  1. Be currently operating within the United States and/or its territories.
  2. Be licensed according to applicable state and federal laws and regulations and maintain all current legal authorization to operate.
  3. Have completed the Medicare Enrollment Application Form CMS-855A and had this form verified by the assigned Medicare Administrative Contractor (MAC), if applicable.
  4. Have established policies and procedures.
  5. Have successfully completed a test Outcome and Assessment Information Set (OASIS) transmission to the state repository, if applicable.
  6. Have met capitalization requirements, if applicable.
  7. Occupy a building in which services are provided/coordinated that is identified, constructed, and equipped to support such services.
  8. Clearly define the services it provides directly or under contract.
  9. Submit all required documents and fees to ACHC within specified time frames.
  10. Be providing home health nursing and at least one qualifying therapeutic service.
    1. The qualifying therapeutic services include physical therapy, speech therapy, occupational therapy, medical social services, and home health aide (Reference in Centers for Medicare and Medicaid Services (CMS) 42 CFR 484.105(f).
    2. A Distinction is a non-qualifying therapeutic service.
  11. Have provided care to a minimum of 10 patients requiring skilled care (not required to be Medicare patients). At least seven of the 10 required patients are receiving skilled care from the Home Health Agency (HHA) at the time of the initial Medicare survey. If the HHA is not able to meet the minimum number of patients required, the initial survey will not be conducted. If the HHA is located in a medically underserved area, they can contact the CMS Regional Office (RO). If the CMS RO determines that the HHA is located in a medically underserved area, the CMS RO may reduce the minimum number of patients from 10 to five. At least two of the five required patients should be receiving skilled care from the HHA at the time of the initial Medicare survey. It is the organization’s responsibility to notify ACHC if it is located in an underserved area.


For more information call (855) 937-2242 ext. 457

ACHC Accreditation – A New Option for California Home Health Licensure

With more than 500 initial licensure applications pending approval in California, home health agencies are being forced to wait up to two years before receiving their license. To help combat this delay, the California Department of Public Health (CDPH) has given home health agencies the option of working with a CMS-deemed accreditation organization to obtain an initial licensure survey. CDPH is encouraging home health agencies to take advantage of this new option in order to expedite their licensure approval process.

The Accreditation Commission for Health Care (ACHC), a nationally recognized accreditation organization known for providing value, integrity, and the industry’s best customer service, is one of the approved accreditors.

“ACHC is ready to immediately accept applications and assist start-up agencies seamlessly through the licensure process,” said Teresa Harbour, ACHC’s Program Director for Home Health, Hospice, and Private Duty.  “Meeting the needs of California providers is essential to ACHC, so we have created accreditation prep tools and resources specific for these providers.”

Faina Neveleva, Administrator of Signature Home Health Care, was grateful for the training and support her agency received from ACHC. She attended the ACHC Home Health workshop in preparation for her agency’s recent accreditation survey.

“The workshops were so educational. Lisa [ACHC Clinical Compliance Educator] was very patient and answered all of our questions,” added Neveleva. “The free ACHC Accreditation Guide to Success workbook tells you exactly what the Surveyors are looking for. We rely on this so much.”

ACHC is accepting applications for home health licensure and accreditation in California and has already started surveying agencies. Once the application is completed, ACHC guarantees agencies will be surveyed within 25 days.

“We were impressed with how simple and straightforward the ACHC application process was and how quickly we were surveyed,” said Neveleva. “Throughout the whole process, our Account Advisor was very knowledgeable and helpful, returning calls usually within an hour and making sure all our questions were answered.”

Partnering with ACHC not only provides a faster route to licensure, it also allows agencies to reap the benefits of accreditation – ensuring compliance with the Medicare Conditions of Participation (CoPs) and the highest quality standards.

VNA Hospice & Palliative Care of Southern California has been accredited for over 20 years and recently switched to ACHC. Paula Natale, Director of Regulatory Affairs, said the organization switched because the ACHC Accreditation Standards are easy to understand and are more applicable to the home health and hospice services provided by the agency.

“It is a way for us to show our patients, payors, and referral sources that we have achieved a higher standard above and beyond the Medicare CoPs and that we are committed to continuously improving the care we provide,” Natalesaid, reflecting on the value of accreditation.

With more than 1,200 accredited home health agencies across the country, ACHC prides itself on the fact that 98 percent of customers say they would recommend ACHC – and Natale agrees.

“I have recommended ACHC to several colleagues,” she said. “Having experience with other accrediting organizations, I can say that the knowledge, professionalism, and customer service from ACHC Account Advisors, Surveyors, and Clinical team is unmatched in the industry.”

This article was published on Home Health Care News on December 20, 2017.

CMS Home Health Sanctions: Protect yourself with ACHC accreditation

25 October_CMS Sanctions_HH






With the implementation of the first phase of CMS sanctions for Home Health providers on July 1, 2013, agencies across the country are rightfully concerned about what resources are available to help them avoid steep penalties and ensure compliance with Medicare Conditions of Participation (CoPs). With fines totaling thousands of dollars per day on the horizon, a strong compliance program achieved through earning and maintaining ACHC accreditation is a key strategy. Since ACHC standards are written for providers, by providers, and incorporate the Medicare CoPs, agencies that choose to become accredited are taking an important step in reducing their risk.

In addition to the widely-recognized benefits of accreditation, the following are examples of how ACHC will help you avoid these sanctions:

  • All condition-level and standard-level violations cited during any on-site survey conducted by ACHC are not subject to the CMS sanctions.
  • For providers who have deemed status, CMS only conducts on-site surveys for complaint or validation purposes, significantly limiting the risk of an on-site visit during which sanctions could be imposed.
  • New Home Health agencies are frequently less familiar with CMS requirements. ACHC providers have access to a variety of resources, as well as a personal Accreditation Advisor and Surveyors with industry-specific experience aimed at helping you before, during and after the accreditation process.

Proper education of staff is also a key component to establishing and maintaining a strong compliance program, especially as it relates to the implementation of policy in direct patient care. During your on-site accreditation survey, your Surveyor will be evaluating staff providing patient care to ensure it is reflective of both professional standards of practice and agency policy. ACHC also provides audit tools to ensure compliance with essential standards related to personnel records, client charts and other required documentation and standards.


  • Directed Plan of Correction: CMS may impose a directed plan of correction developed by CMS or a temporary manager. If compliance is still not achieved, CMS could impose one or more additional sanctions until compliance is achieved or the agency is terminated.
  • Directed In-Service Training:  CMS could require HHA staff to attend in-service training programs if CMS determines that education would lead to correction of deficiencies. Providers of educational programs must be approved by CMS or the State, and the cost associated with the in-service training would be the responsibility of the HHA.
  • Temporary Management: CMS could impose the temporary management sanction if CMS determines that management limitations contribute to a HHA’s inability to correct deficiencies. The HHA would be required to pay for the salary and additional costs incurred.


Civil Money Penalties – CMS may impose a civil money penalty against an HHA for either the number of days the HHA is not in compliance or for each instance the HHA is not in compliance. Penalties can range up to $10,000 per day.

  • Suspension of payment for all new admissions – CMS may suspend payment for all new Medicare admissions regardless of whether the Condition Level deficiencies pose immediate jeopardy.


CMS-stated sanctions are applicable in the event of a condition-level deficiency, unless the standard-level deficiency is considered to impose significant harm to an individual or if an agency has a standard-level deficiency previously found to be a conditional-level deficiency. CMS will delay the application of civil money penalties, payment suspension and the Informal Dispute Resolution (IDR) process until July 1, 2014. For more information about the CMS sanctions, read the Federal Register, Vol. 77, No. 217 published November 8, 2012. Read more by downloading the CMS PDF › ›

Listen to the original Podcast from November 2012››

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Ready for accreditation? Contact ACHC at (855) 937-2242 to learn more.

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Top 3 Home Health Deficiencies for ACHC Customers

Top 3 Home Health Deficiencies for ACHC Customers

By Julie Pazun

We are often asked about the most commonly cited areas on a home health survey. Below are the top 3 cited areas and some tips on how to ensure that your agency will be in compliance during the on-site survey.

HH5-2 F There is a comprehensive assessment that includes a review of all medications the patient is currently taking (prescription and non-prescription). The organization performs a drug regimen review.

This ACHC standard is linked to the CMS Conditions of Participation 484.55. Organizations often are deficient in this area because the clinician does not ensure that the medication profile is updated or there is no evidence that the drug regimen review has occurred. Often times, surveyors will find documentation of new medications in the clinical notes, but the nurse has not updated the medication list.  In order to ensure compliance, the organization should confirm the staff is asking at each patient visit if there have been any changes to their medications and also request to see the medication bottles during the visit.

HH 5-11F The agency defines the duties of the home health aide and ensures that they are implemented in patient care.

This ACHC standard is linked to the CMS Condition of Participation 484.36. Deficiencies are sited here when the care provided by the aide deviates from the written plan of care.  Organizations should ensure that their aides are properly in-serviced to perform the tasks as outlined on the aide plan of care. If these tasks are not able to be performed as ordered, there should be evidence in the record that the aide has contacted the case manager for revision of the plan of care. The supervising nurse should be evaluating the aide care plan during the aide supervisory visits to ensure that the tasks ordered still meet the needs of the patient. The aide care plan should be updated as the patient’s needs change.

HH5-8B The agency’s personnel promptly alert the physician to any changes that suggest a need to alter the plan of care.

This ACHC standard is linked to the CMS Conditions of Participation 484.18. Deficiencies are sited here when there is evidence in the clinical record that assessment findings fall outside the norm for the patient or progression towards the expected outcome for the patient. This could include elevated vital signs, abnormal lab results, deteriorating wound conditions or deteriorating physical/mental conditions in which the patient would benefit from a change in the plan of care, including additional services.

For more information on this topic, contact your Accreditation Advisor at (855) 937-2242.

Home Health | Hospice | DMEPOS | Private Duty
Pharmacy | Sleep  | Behavioral Health

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About the Author:

Julie Pazun ThumnailJulie Pazun has been a Registered Nurse for over 20 years, working in both acute care as well as community settings. She is responsible for the development and implementation of the Home Health, Hospice, Private Duty, Behavioral Health and Convenient Care Clinic Accreditation Programs. In 2009, Julie began her career with ACHC as a Surveyor and joined the management team in 2011.

Getting Ready to Open Your Own Business? Make Sure You Answer Your Phone/Email/Social Media!

Starting a business is tough, especially in this uncertain economy. If you are ready to take the next step in opening a Home Health, Hospice, DMEPOS or any other business for that matter, your best strategy is to first know what you are up against.  Anyone who has taken a “Business 101” class knows that roughly half of new businesses close within one fiscal year. But here are a few interesting facts to help shape your business plan:


  • 80% of your revenue will come from only 20% of your clients.
  • Keep all customers happy, but remember that your repeat customers are EXTREMELY valuable.


  • Less than 25% of small businesses respond within 5 minutes.
  • If the business calls/contacts back in less than 10 minutes, the potential client will be more responsive to discuss the service/product offering.
  • Remember there are many ways to open up conversations with clients: Phone/Email/Social Media.


  • Most small business reps give up after 2 attempts to reach a potential customer.
  • That’s why it is important to contact as soon as possible after the inquiry. The longer the business waits the more likely the potential client found a substitute.

Slowing sales and unforeseen economic/business conditions are the largest challenges businesses face – be it a start-up or an established business. Your best bet is to fully understand the needs of your market, join local associations, and connect in your community.  But as the data shows, your number one priority is to be accessible and responsive to potential and current clients.

*Check out the inforgraphic at

How Does the Fiscal Cliff Affect Your Business?

To start, President Obama signed the American Taxpayer Relief Act of 2012 into law to stave off the fiscal cliff, which left many home health organizations relatively unchanged for another year. Here are the highlights affecting Home Health and Hospice:

• There are no cuts to Medicare home health or hospice care benefits, payments, or payment rates

• Home Health will not see Medicaid cuts

• Protection against the Medicare outpatient therapy cap is in effect through the end of the year (2013)

Finally, the Senate bill created a Long Term Care Commission that will be in charge of developing a plan to meet the needs of the aging population. The commission will be a group of 15 members appointed by Mr. Obama, as well as other congressional leaders.

This is good news to start off the New Year for home health and hospice facilities, however community pharmacists may have gotten the rotten end of the deal. A provision in the bill stated that there will be a competitive bidding structure for diabetes test strips (which could save the Medicare program upwards of $600 million). This could seriously affect the industry and cause community pharmacists to stop providing diabetes test supplies to Medicare beneficiaries. John Coster, of the National Community Pharmacists Association (NCPA), stated his concern, “NCPA has repeatedly outlined to Congress and Medicare officials the shortcomings in such an approach. Round one of the competitive bid program has validated NCPA’s concerns, including waste in mail order and patients’ strong preference for a face-to-face health care experience with a local provider.”

What are your thoughts?  Please share below!

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Survey The Expert Podcast: Episode 4 “Becoming Accredited”

Album cover for Survey The Expert: ACHC[iOS users]


In today’s Survey The Expert podcast, we’ll be joined by Lisa Feierstein, VP of Sales for Active Health.  She will discuss the process her organization went through to become accredited with ACHC, and give some tips on how to make accreditation easier for you.

Lisa Says:
• Accreditation takes time and energy, but
• Will help grow your business, and
• ACHC Surveyors are helpful and encouraging

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Survey The Expert Podcast: Episode 3

Album cover for Survey The Expert: ACHC[iOS users]


In today’s Survey The Expert podcast, we’ll learn more about CMS’s recent ruling that will affect Home Health agencies. Julie Pazun, ACHC’s Home Health, Hospice, and Private Duty Clinical Manager, will highlight the key elements of the document.

However, it will be wise for all Home Health agencies to become familiar with the final ruling by going to Note that some of the ruling are not in effect until July 1, 2013, and others July 1, 2014.

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