The main goal of a home health agency (HHA) is to provide high-quality in-home medical care and support to their patients. In order to make sure that this is achieved, HHAs are routinely inspected and surveyed, typically conducted by governmental organizations like the State Department of Health or by accrediting bodies like The Joint Commission, ACHC, and CHAP. They conduct both announced and unannounced visits to home health agencies to assess their compliance with standards, policies, and procedures.

These surveys are essential to ensuring that home health agencies continue to provide high-quality care, and citations given during audits may have serious repercussions.

In this blog post, we will discuss common citation reasons during home health agency surveys and the importance of avoiding these citations to maintain the reputation and accreditation of the agency.

Overview of the home health agency survey process

Home health agency surveys are conducted to assess the quality of care provided by the agency and to determine compliance with state and federal health care rules and regulations. The survey process typically involves three main parts:

• Administrative

This part of the survey is concerned with the administrative aspects of the home health agency. It includes evaluating the agency's policies and procedures manual, and processes related to patient care and safety. The surveyor may also review the agency's staffing patterns, quality improvement programs, emergency preparedness, and other administrative functions.

• In-home Visit

The in-home visit is an essential part of the HHA survey. During this part, the surveyor visits the patients' homes to assess the quality of care provided by the clinicians and to determine if the patient is in the condition that the HHA reports.

The surveyor observes the patient's environment, evaluates the clinician's skills and knowledge, and reviews the patient's care plan to ensure that it is appropriate and up-to-date.

Surveyors identify areas where the agency has failed to comply with federal regulations. These deficiencies are cited and the agency is required to write a plan of correction. 

• Documentation

The documentation part of the survey focuses on the agency's record-keeping practices. Surveyors review the agency's documentation to ensure that it is accurate, complete, and timely. 

This includes the patient list, patient records, medication administration records, plan of care, and other relevant documents. The surveyors also look for evidence of communication between the agency, the patient, and other healthcare providers.

Common reasons for citations 

Several factors can contribute to citations issued during home health agency surveys. Here are some of the most common reasons:

• Failure to comply with federal and state regulations

Home health agencies must comply with a set of regulations established by CMS or by accrediting organizations, such as the Joint Commission. Failure to meet these conditions of participation (CoP) can result in citations. 

Common compliance issues include lack of documentation, inadequate staff training, and failure to follow safety protocols.

• Inadequate care planning

Agencies are required to develop a comprehensive plan of care (POC) for each patient they treat. It is a critical document that outlines the specific care and services that a patient requires based on their individual needs. 

HHAs are responsible for developing a comprehensive POC in collaboration with the patient, their family members, and healthcare providers.

If the surveyor identifies that the HHA is not following the patient's POC, the agency may be cited. This could include issues related to medication administration, missed visits, or failure to provide necessary services. It is important for home health agencies to ensure that they are following the patient's POC to ensure that they are providing the appropriate care and services needed to achieve the desired outcomes.

• Deficiencies in patient care

Providing high-quality care to their patients is the main responsibility of HHAs. If a surveyor identifies that the agency has failed to meet the standard of care for a patient, the agency may be cited. This could include issues related to medication management, wound care, or patient safety.

• Failure to maintain accurate and complete patient records

Accurate and complete patient records, including assessments, care plans, and progress notes, must be maintained. If the surveyor identifies that the agency has failed to maintain accurate and complete patient records, the agency may be cited. 

HHAs need to make sure they have the right policies and procedures in place to keep up-to-date, comprehensive patient records. This includes training staff members on proper documentation practices, regularly reviewing and auditing patient records and visit notes for completeness and accuracy, and promptly addressing any issues or discrepancies that are identified. 

• Inadequate staff training 

Home health agencies must ensure that their staff members are properly trained to provide care to patients. Failure to train staff members adequately may result in citations. 

For example, the agency may be cited for not providing staff members with the necessary training to use medical equipment or for not providing staff members with adequate training on patient confidentiality.

• Inadequate infection control measures

Infection control is critical in the home health industry to prevent the spread of infections and protect the health and safety of patients, staff members, and others in the community.

If the surveyor identifies that the home health agency has inadequate infection control measures, the agency may be cited. This could include issues related to improper hand hygiene practices, inadequate cleaning and disinfection of equipment and supplies, failure to use appropriate personal protective equipment (PPE), and failure to properly isolate patients with infectious diseases.

• Failure to report events

During surveys, the surveyors may review the agency's policies and procedures related to reporting events such as incidents, injuries, and infections. 

If the surveyors find that the agency failed to report an event that was required to be reported, they may issue citations and penalties.

It is important for home health agencies to have clear policies and procedures in place for reporting events and for staff to be trained on these policies. Failing to report an event could potentially put patients at risk and may result in negative consequences for the agency.

Consequences of citations

Citations issued during surveys can have significant consequences. Some of these may include:

• Negative impact on the reputation of the home health agency

• Loss of accreditation or certification

• Legal and financial sanctions

Strategies to help avoid citations

The best strategy to avoid citations during surveys is to maintain a culture of compliance and continuous improvement. This involves developing and implementing policies and procedures that comply with all applicable regulations and standards, as well as regularly monitoring and evaluating the agency's performance to identify and address any areas of non-compliance or quality improvement.

Some specific strategies that can help in achieving compliance during surveys include:

• Conduct regular self-audits and mock surveys to identify and address potential compliance issues before they are cited during a formal survey.

• Ensure that all staff members are properly trained and educated on all applicable regulations and standards, and regularly provide refresher training to reinforce key concepts and principles.

• Maintain accurate and complete documentation of all patient care and services, and ensure that your agency has a clear documentation process in place. 

• Foster a culture of open communication and transparency, where staff members feel comfortable reporting any potential compliance issues or quality concerns.

Final thoughts

Avoiding citations during home health surveys is crucial for maintaining the reputation and success of the home health agency. Citations can result in severe consequences, such as loss of accreditation, financial penalties, and legal action. 

Maintaining compliance with regulations, providing high-quality care, and implementing effective strategies to prepare for a survey can help ensure the trust of patients and the community and save the agency resources that would otherwise be spent on corrective action plans.