CMS Survey Preparation: A Practical Guide for Hospice and Home Health Agencies

Understanding the CMS Survey Process

CMS surveys of hospice and home health agencies are conducted by State Survey Agencies under contract with CMS. For both program types, surveys are typically unannounced and may be triggered by complaint investigations, poor CASPER or CAHPS performance, or random selection as part of a standard survey cycle. Surveys generally recur on a regular basis, often approximately every three years, though timing varies by state survey agency capacity and compliance history. For home health, CMS has specific protocols under the Home Health Survey Protocol, while hospice surveys follow the Hospice Survey Protocol, both of which outline how surveyors will select sample records, conduct interviews, and assess the environment of care.

Understanding how surveyors build their sample is critical. For hospice, surveyors typically select a random sample of open and recently discharged patients across different levels of care (routine home care, continuous home care, inpatient respite, and general inpatient). For home health, the sample will include patients across different disciplines, start-of-care periods, and OASIS assessment windows. Agencies that can quickly produce a census report, an OASIS assessment log, and a list of recent discharges are in a far stronger position at the start of a survey than those that must scramble to pull records.

Before the Surveyors Arrive: Annual Readiness Review

Survey readiness is not a one-time sprint; it is a year-round operating posture. The most survey-ready agencies conduct a formal internal readiness review at least twice per year, assessing their performance against every CoP standard and documenting their findings. Agencies that review 100% of active charts are generally better prepared than agencies relying solely on spot sampling, because surveyors build their sample from your entire census, not just the records you have already reviewed. A readiness review should include a chart audit of a random sample of 10–15% of current patients, a review of all aide supervision records, a review of QAPI program documentation (including meeting minutes and performance improvement projects), and a review of all incident reports and grievance records for the preceding 12 months.

Findings from the readiness review should be documented, assigned to an owner, and tracked to resolution. This documentation serves two purposes: it demonstrates to surveyors that your agency has an effective QAPI process, and it creates a defensible record that you identified and addressed the issue before the survey, rather than being cited for it.

During the Survey: What to Expect

When surveyors arrive, they will present their credentials and request to meet with agency leadership. Have a designated survey coordinator who is responsible for escorting surveyors, facilitating record requests, and tracking what has been reviewed and what findings have been discussed. Do not leave surveyors unattended with staff who have not been briefed on survey protocol.

Surveyors will conduct staff interviews, patient and family interviews (often by phone for home-based patients), and record reviews. Ensure that every staff member knows to answer questions truthfully, specifically, and within the scope of their own knowledge; they should not speculate about agency policy or practices they are not directly involved in. The survey coordinator should be available to provide context and documentation when staff are unsure of a specific process.

After the Survey: The Statement of Deficiencies and Plan of Correction

If deficiencies are cited, CMS will issue a Statement of Deficiencies (Form CMS-2567) within 10 days of the survey exit. Your agency has 10 days to submit a Plan of Correction (PoC) that addresses each cited deficiency. The PoC must describe the corrective action taken, the completion date, the monitoring process, and the individual responsible. Submitting a well-organized, specific PoC, with documentation that corrective action has already been taken for immediate corrections, significantly reduces the likelihood of a follow-up survey.