Accreditation & Surveys Surveys and certification
Accreditation guide
Surveys and certification
Medicare certification comes through either a state survey agency’s initial survey or an accreditor’s deemed survey; in both cases the MAC reviews the enrollment first. State licensure surveys are separate and run under state law.
Educational summary, last reviewed October 17, 2026. Not legal advice — confirm with the state licensing agency or counsel.
Last reviewed October 17, 2026. 10 findings: 10 verified. 1 time-sensitive, flagged with a recheck date. How findings are sourced and labelled.
1Who does what
Two routes
VerifiedUnder SSA §1865(a), CMS may approve accreditors whose standards and survey processes meet or exceed its own; accreditation “is voluntary and is not required for Medicare participation.” The default route is certification by the state survey agency.
Source: CMS State Operations Manual, Chapter 2Federal Register 2026-13918 (TJC home health, July 10, 2026)
The MAC first
VerifiedAccreditors may not survey initial applicants until the MAC has reviewed the CMS-855A and recommended approval; applicants seeking deemed status still contact the state survey agency for certification materials (SOM ch. 2 §2003C).
2Initial surveys and their priority
Home health census
VerifiedEach applicant must have provided skilled home health services to at least 10 patients before a survey, with at least 7 receiving care at the time of the initial survey (SOM ch. 2 §2008B). No hospice-specific census was found in the SOM.
State agency priority
VerifiedIn the FY 2027 Mission and Priority Document, 36.9-month recertification is Tier 1; initial certification is Tier 2 only where CMS finds an access-to-care issue, and Tier 3 otherwise, including where more than 150 days have passed since the MAC recommended approval and a deeming option exists.
During the moratorium
VerifiedInitial certification surveys of agencies not exempt from the nationwide moratorium that began May 13, 2026 “shall not continue for the duration”; applications received before May 13, 2026 are exempt and their surveys may continue with an approved CMS-855A.
Time-sensitive. Recheck after about November 13, 2026.
With all requirements met, the agreement is effective on the last day of the survey; with standard-level deficiencies only, on the date an acceptable plan of correction is received (SOM ch. 2 §2008D).
3Survey frequency
Every 36 months
VerifiedEach home health agency is subject to a standard survey within 36 months (SSA §1891(c)(2)(A)), tracked as 36.9 months; surveys are to be unpredictable, not in the same month each year (SOM ch. 2 §2008F).
Source: CMS State Operations Manual, Chapter 2CMS FY 2027 Mission and Priority Document
4Deficiencies and plans of correction
Form CMS-2567
VerifiedThe state agency sends the provider Form CMS-2567 within 10 working days of the survey; with deficiencies, the provider has 10 calendar days to return a plan of correction. The 2567 is the public record of deficiencies (SOM ch. 2 §2728).
Informal dispute resolution
VerifiedHome health agencies and hospices may request informal dispute resolution of condition-level findings in writing within the same 10-day period; it does not delay enforcement (42 CFR 488.745, 488.1130).
Source: 42 CFR 488.74542 CFR 488.1130
5State licensure surveys
Separate from certification
VerifiedState licensure surveys run under state law; state agencies coordinate licensure visits with certification visits where possible (SOM ch. 2 §2008E). Several states accept accreditation in place of a routine licensure survey.
In practice: See the map: accreditation in place of a state survey.
Official sources
Revision history
| Date | Change |
|---|---|
| 2026-10-17 | First published |
About this guide. Published and maintained by Paloma Health Technologies; Findings are cited to official sources, dated and status-labelled; see the editorial policy. Educational summary, last reviewed October 17, 2026. Not legal advice — confirm with the state licensing agency or counsel.
Questions
Surveys and certification: common questions
How many patients must a new home health agency serve before its Medicare survey?
At least 10 receiving skilled services, with 7 under care at the survey (SOM ch. 2 §2008B).
Does accreditation replace the state license?
No. Where a state requires a license, accreditation does not replace it; some states accept accreditation in place of their routine licensure survey.