CMS Issues Survey Guidance for Home Health Agencies' New "Acceptance-to-Service" Policy Requirement — Here's What Changes, Effective Immediately

The Centers for Medicare & Medicaid Services (CMS) has issued new survey guidance instructing State Survey Agencies on how to enforce a home health agency requirement that has technically been in effect since January 1, 2025, but that surveyors have lacked formal interpretive guidelines to cite until now. The memorandum, designated QSO-26-13-HHA and titled "Acceptance-to-Service Requirement for Home Health Agencies and updated Guidance," was issued July 15, 2026, by the Director of CMS's Quality, Safety & Oversight Group (QSOG), and is effective immediately.

The memo operationalizes a new standard added to the Home Health Agency (HHA) Conditions of Participation by the Calendar Year 2025 Home Health Prospective Payment System (HH PPS) final rule, requiring every Medicare-certified home health agency to develop, implement, and annually review a formal policy governing which patients it will and will not accept for care. CMS is pairing that requirement with two new survey citation tags — known as G-tags — added to the State Operations Manual, along with a separate, unrelated clarification about who qualifies to serve as an HHA's administrator. Below, HealthBridge US walks through what the acceptance-to-service policy requires, why CMS built it, how surveyors will evaluate compliance, and what it means for home health agencies, hospitals and discharge planners, and the patients and families who depend on home health care.

Quick-Read Summary

Before the details, here is the essential rundown of what's changing. Effective January 1, 2025, and now backed by formal survey guidance as of July 15, 2026, every Medicare-certified home health agency must develop, implement, and review at least annually a written "acceptance-to-service" policy that it applies consistently to every prospective patient referred for home health care. That policy must address, at a minimum, four factors tied to the agency's actual capacity to provide care: the anticipated needs of the referred patient, the agency's current case load and case mix, its staffing levels, and the skills and competencies of its staff. CMS has added two new survey citation tags to the State Operations Manual to enforce this: G990, covering the acceptance-to-service policy itself, and G992, a related requirement that HHAs make accurate, current information about the services they offer publicly available and review that public information whenever their services change, but no less than once a year. Separately, and unrelated to the acceptance-to-service requirement, CMS used this same memo to clarify a longstanding point of confusion about HHA administrator qualifications, specifying which set of requirements applies depending on whether an individual began serving as administrator before or after January 13, 2018. State Survey Agencies are directed to begin citing noncompliance using the new G-tags immediately, and CMS has released an advance copy of the updated State Operations Manual guidance to support that.

Why This Matters Right Now

Home health referral and admission has become one of the more visibly strained junctures in the post-acute care system. Hospitals discharging patients who need skilled nursing or therapy services at home, and other referral sources such as physician offices and skilled nursing facilities, have increasingly reported difficulty placing patients with a home health agency willing and able to accept them — a dynamic driven largely by home health workforce shortages and rising demand for home-based care as the Medicare population ages. When a home health agency declines a referral, or accepts a referral it is not actually staffed to serve well, the consequences ripple outward: hospitals face longer discharge delays and the bed-capacity and cost pressures that come with them, patients can miss the early window in which home-based rehabilitation and skilled nursing care is most effective, and families are sometimes left coordinating care informally while a suitable agency is found.

CMS's acceptance-to-service requirement is a direct regulatory response to that dynamic, though a narrowly targeted one. Rather than requiring home health agencies to accept a minimum share of referrals, or setting a maximum allowable time to initiate care, the requirement instead focuses on process: it requires every HHA to have a consistent, documented, capacity-based method for deciding which referrals to accept, rather than making accept-or-decline decisions on an ad hoc, inconsistent, or opaque basis. CMS's stated rationale, laid out in this memo, is that a documented and consistently applied acceptance process reduces the delay between when a patient becomes eligible for home health care and when care actually begins, and helps ensure that referring hospitals, physicians, and patients themselves can better match a prospective patient to an agency actually equipped to meet that patient's needs — reducing the friction of applying to an agency, waiting, and being declined only after the fact.

By the Numbers: The Scale of Home Health Care

The requirement touches a sizable share of the Medicare program. As of recent CMS counts, roughly 12,089 home health agencies operate as Medicare-certified providers nationwide, each subject to the Conditions of Participation this memo's guidance interprets. Home health care overall serves a substantial patient population: an estimated 3 million Medicare fee-for-service beneficiaries used home health services in a recent year, out of a broader national total of roughly 12 million Americans receiving home health care annually across all payer types, including Medicare Advantage, Medicaid, and private insurance. Every one of the roughly 12,089 Medicare-certified agencies in that population has been required, since January 1, 2025, to maintain a compliant acceptance-to-service policy — meaning this memo's new survey guidance and citation tags apply, in principle, across the entire certified home health industry as State Survey Agencies work through their normal recertification survey cycles.

Background: How We Got Here

The acceptance-to-service requirement did not originate in this July 2026 memorandum. It was created more than a year and a half earlier, when CMS issued the Calendar Year 2025 Home Health Prospective Payment System Rate Update and Home Infusion Therapy and Home IVIG Services Payment Update final rule on November 1, 2024, published in the Federal Register on November 7, 2024, at 89 FR 88354. That rule — CMS's annual vehicle for updating home health payment rates and related policy — did far more than adjust payment rates; among its other provisions, it amended the HHA Conditions of Participation at 42 CFR Part 484 by adding a new standard at §484.105(i) governing patient acceptance-to-service policies, with an effective date of January 1, 2025.

CMS's stated reasoning for adding this standard, both in the original 2024 final rule and reiterated in this July 2026 memo, centers on the structural mismatch between how home health agencies operate and how patients and referral sources try to find them. Every HHA is required to furnish skilled nursing services plus at least one other therapeutic service — physical therapy or occupational therapy, for example — provided on a visiting basis in a patient's residence. But the specific mix of services any given HHA actually offers varies considerably from agency to agency, and that variation, combined with each agency's own staffing and capacity constraints at any given moment, creates real difficulty for referral sources and patients trying to identify an HHA actually equipped to meet a specific patient's needs. CMS's view, as expressed in this memo, is that this variation "necessitates an HHA-specific approach to accepting referrals for care," distinct from and in addition to the agency's obligations under the individualized plan-of-care requirements at 42 CFR § 484.60, which govern the clinical plan for a patient once accepted rather than the threshold decision of whether to accept that patient in the first place.

The acceptance-to-service standard was one relatively small piece of a much larger rulemaking. The CY 2025 HH PPS final rule primarily set the annual Medicare payment rate update for home health agencies for calendar year 2025, alongside separate updates to the Home Health Quality Reporting Program, an expansion of the Home Health Value-Based Purchasing Model, and payment updates for home infusion therapy and home intravenous immune globulin (IVIG) services — provisions that, unlike the acceptance-to-service standard, are unrelated to the survey and certification guidance addressed in this July 2026 memo. It is worth understanding that context because it explains why a Conditions of Participation change with real day-to-day compliance implications for HHAs first appeared inside an annual payment rule rather than as a standalone regulatory action: CMS routinely uses its annual home health payment rulemaking as a vehicle for Conditions of Participation and quality-program changes as well, meaning HHA compliance staff need to review the full scope of each year's HH PPS final rule, not just its payment-rate provisions, to catch changes like this one.

Between the rule's January 1, 2025 effective date and this July 2026 memo, HHAs were technically already required to comply with the acceptance-to-service standard, but State Survey Agencies lacked the interpretive guidelines and citation tags needed to formally evaluate and cite noncompliance during surveys. This memo closes that gap by adding the necessary survey guidance to the State Operations Manual (SOM) Appendix B, the reference document surveyors use to evaluate HHA compliance with federal Conditions of Participation, and by making conforming updates to a related, previously ambiguous provision.

What the Acceptance-to-Service Policy Must Include

The core of the new requirement, now cited under survey tag G990, requires every HHA to develop, implement, and maintain — through at least an annual review — a written patient acceptance-to-service policy that is applied consistently to each prospective patient referred for home health care. CMS is explicit that the policy must be applied equally and consistently across referrals, rather than serving as a case-by-case discretionary judgment call untethered to documented criteria.

At minimum, the policy must address four specific factors, all tied to the HHA's actual capacity to provide care rather than to administrative or financial considerations. The first is the anticipated needs of the referred prospective patient — what clinical services and level of care the patient is likely to require, based on available information such as diagnosis, recent hospitalization history, and specific orders from the patient's medical provider. The second is the HHA's own case load and case mix, meaning the number and complexity of patients the agency is currently serving, which shapes how much additional capacity it realistically has available. The third is the HHA's current staffing levels. The fourth is the skills and competencies of the HHA's staff — whether the clinicians and therapists currently on staff have the training needed to serve the specific needs anticipated for the referred patient.

CMS's interpretive guidance in this memo acknowledges that not all of a prospective patient's needs will be fully known at the time of referral, but states that general diagnostic information, recent hospitalization details where relevant, and specific physician orders should give an HHA a reasonable basis to anticipate a patient's overall needs and determine, against the four required criteria, whether the agency is or is not an appropriate fit. HHAs retain flexibility to expand their policies beyond these four minimum elements to address other procedural concerns or challenges specific to their own referral and acceptance process, but the four core criteria represent a compliance floor that surveyors will check for directly. Surveyors are instructed to review each HHA's written acceptance-to-service policy to confirm it addresses all four required elements, and CMS is explicit that this policy is a distinct, HHA-level document, separate from the individualized plan of care developed for a specific patient once that patient has already been accepted for services under §484.60.

What a "G-Tag" Actually Is

For readers outside the world of Medicare survey compliance, it is worth briefly explaining what a G-tag is and why CMS's addition of two new ones is the operative mechanism of this memo. The State Operations Manual is CMS's master reference document for how State Survey Agencies conduct Medicare and Medicaid provider surveys, and Appendix B is the volume specifically covering home health agencies. Within that appendix, each individual regulatory standard or condition an HHA must meet is assigned a short alphanumeric identifier — a "tag" — beginning with the letter G for home health agency standards, paired with detailed interpretive guidelines explaining, in plain language, what surveyors should look for when evaluating compliance with that specific regulatory provision.

When a surveyor identifies noncompliance during an inspection, they cite the specific tag associated with the requirement that was not met, and that citation becomes part of the facility's official survey record. Tags are typically also associated with a scope-and-severity framework surveyors use to characterize how serious and how widespread a given deficiency is, which in turn affects what corrective action is required — ranging from a standard-level deficiency, which generally requires the HHA to submit and implement an acceptable plan of correction, up to more serious condition-level findings, which can trigger more substantial compliance consequences depending on the specific regulatory area and pattern of noncompliance involved. Before this memo, no tag existed specifically covering the acceptance-to-service standard or its related public-information requirement, which meant that even though HHAs were legally bound by both requirements starting January 1, 2025, surveyors had no standardized citation mechanism, paired with interpretive guidance, to formally evaluate and document noncompliance during a survey. The addition of G990 and G992 fills that specific gap.

The Public Transparency Requirement: G992 and the Care Compare Data Pipeline

Working in tandem with the acceptance-to-service policy itself, CMS added a second, related standard, now cited under survey tag G992, requiring HHAs to make accurate information about their services — and any limitations on those services related to specialty service types, service duration, or service frequency — available to the public, and to review and update that public-facing information whenever their services change, but no less often than annually.

CMS does not mandate a specific method or channel for making this information public; agencies commonly do so through some combination of the Medicare Care Compare website, their own websites, and printed materials such as brochures. CMS's guidance defines what counts as a "change" triggering the review-and-update obligation fairly broadly: adding, discontinuing, temporarily pausing, or restricting a service all qualify. The memo offers concrete examples, including a staff member's extended leave of absence — for reasons such as caring for a family member, recovering from a serious illness or procedure, or maternity leave — or the addition of a new contracted employee who begins providing a service, such as speech-language pathology, that the agency did not previously offer. CMS's expectation is that HHAs update their publicly available service information whenever they anticipate that a given service will be unavailable for a period of roughly three to six months, rather than waiting for a formal annual review cycle to catch a longer-term gap.

The memo also details, for the first time in this level of specificity, exactly how CMS's own public reporting infrastructure sources this information. CMS extracts data about which services an HHA offers — skilled nursing care, physical therapy, occupational therapy, speech therapy, medical social worker services, and home health aide services — from the CMS-1572 survey report form, on which "Services Provided" information is recorded directly from agency staff during CMS initial and recertification surveys, and which states can also update outside a survey cycle. That data flows into CMS's iQIES database, which in turn feeds public-facing tools including the Care Compare website. To update this information between formal survey cycles, HHAs are instructed to first ensure the change is reflected in PECOS (Medicare's provider enrollment system) and then reach out to their state's OASIS Education Coordinator or OASIS Automation Coordinator to request that the corresponding iQIES record be updated.

CMS builds a specific, practical safe harbor into this requirement worth flagging for both HHAs and surveyors: because updates to HHA provider demographic information do not occur on Care Compare in real time, and can take up to six months to actually appear on the public website after a change is requested, surveyors are instructed not to cite an HHA for outdated or inaccurate information on Care Compare so long as the agency can produce evidence that it already requested the relevant correction or update through the PECOS-to-iQIES process described above. In effect, CMS is holding HHAs accountable for initiating timely update requests, not for the speed of CMS's own backend data-processing pipeline.

A Separate Clarification: Who Qualifies as an HHA Administrator

Distinct from the acceptance-to-service requirement, this memo also uses the opportunity of an SOM Appendix B update to clarify a longstanding, unrelated point of confusion under an existing standard: who qualifies to serve as an HHA's administrator, cited under tag G1052. CMS is explicit that nothing about the underlying substantive requirement has changed since it took effect in 2018 — this is a clarification of existing guidance, not a new standard or a revised standard, addressing a question CMS says it "frequently" receives from both HHAs and surveyors.

The administrator standard at 42 CFR § 484.115(a) has, since a 2017 final rule (82 FR 4556, published January 13, 2017) took effect, applied two different qualification tracks depending on when an individual began serving in the administrator role. Individuals who were already acting as an HHA's administrator before January 13, 2018 may continue in that role so long as they meet the original, broader qualification standard under §484.115(a)(1): being a licensed physician, being a registered nurse, or having training and experience in health service administration together with at least one year of supervisory administrative experience in home health care or a related health care program. Individuals hired into the administrator role on or after January 13, 2018, however, must meet the newer, more specific standard under §484.115(a)(2): being a licensed physician, a registered nurse, or holding an undergraduate degree (which CMS's guidance clarifies means either a bachelor's or an associate degree), combined with experience in health service administration and at least one year of supervisory or administrative experience in home health care or a related health care program.

CMS notes that this date-based distinction was already described in the preamble to the original 2017 final rule, but says it had not previously been made clear within the regulatory text or interpretive guidance itself, which is why the agency frequently fielded questions about it from both surveyors and HHAs. The July 2026 memo resolves that ambiguity by adding an explicit clarifying note directly to the SOM Appendix B guidance for tag G1052, so that surveyors and agencies alike have a single, authoritative reference for which qualification track applies to a given administrator based on their hire or role-assumption date.

A Hypothetical Illustration

The interaction between the acceptance-to-service policy's four required criteria can be easier to follow with a concrete, hypothetical example — illustrative only, and not drawn from any specific real agency. Consider a home health agency that primarily staffs registered nurses and physical therapists, with only limited in-house wound care specialization and no speech-language pathologist currently on staff, following the recent departure of the one clinician who provided that service. Under a properly implemented acceptance-to-service policy, that agency's intake staff would evaluate a new referral against its documented criteria: does the referred patient's anticipated needs — based on diagnosis, recent hospitalization, and physician orders — fall within services the agency can currently provide (anticipated needs); does the agency currently have room in its case load given its existing patient mix (case load and case mix); does it have enough available nursing and therapy staff capacity to take on the new patient without compromising care for existing patients (staffing levels); and do the clinicians actually available have the right skill set for this specific patient, such as complex wound care experience if the referral involves a wound care–intensive case (skills and competencies).

If a prospective patient's needs include speech-language pathology services the agency does not currently have staff to provide, a consistent application of that same documented policy would lead the agency to decline the referral — and, under the related G992 requirement, that same gap should already be reflected in the agency's public-facing service information, ideally before the referral is even submitted, rather than surfacing only when the referral is declined. This is the coordination CMS's guidance is aiming for: a referring hospital's discharge planner checking an agency's publicly listed services in advance should, in principle, already see that speech-language pathology is currently unavailable, reducing the odds of a referral being submitted, reviewed, and declined after avoidable delay.

How Surveyors Will Evaluate Compliance

Because this memo adds citation tags rather than creating wholly new inspection protocols, the acceptance-to-service and public-information requirements will be assessed as part of HHAs' existing survey cycle, using the same State Operations Manual Appendix B framework surveyors already use to evaluate compliance with the full range of HHA Conditions of Participation. For G990, surveyors are directed to review the HHA's written acceptance-to-service policy directly and confirm that it addresses all four required elements — anticipated patient needs, case load and case mix, staffing levels, and staff skills and competencies — and, implicitly, to assess whether the agency's actual referral decisions reflect consistent application of that written policy rather than treating the document as a formality disconnected from real practice.

For G992, surveyors are directed to confirm that the HHA is making accurate service information publicly available and reviewing it on the required cadence — at least annually, and whenever an actual service change occurs — while applying the specific safe harbor described above for any discrepancies traceable to CMS's own Care Compare update lag rather than to the HHA's own failure to request a correction. Because CMS explicitly separates the acceptance-to-service policy (G990) from the individualized plan of care under §484.60, surveyors evaluating an HHA's intake and acceptance practices are expected to treat the two as distinct compliance areas addressing different points in a patient's care journey — the threshold decision to accept a referral, versus the clinical plan developed once a patient has already been accepted.

Noncompliance identified under either G990 or G992 is cited using the new tags, consistent with CMS's standard survey and enforcement framework for HHA Conditions of Participation, under which cited deficiencies typically require the agency to submit an acceptable plan of correction and can, depending on severity and pattern, lead to further compliance action if problems are not remediated.

Context: A Regulatory Response to a Capacity Crunch — With Limits

It is worth situating this requirement within the broader, ongoing conversation about home health referral capacity that has been building across the industry for several years. Home health providers nationally have reported rising referral rejection rates even as demand for home-based care has climbed, a dynamic that industry analysts and hospital discharge planners alike have tied primarily to home health workforce shortages and the resulting mismatch between referral volume and agencies' actual staffing capacity at any given moment. The consequences of that mismatch extend well beyond any single home health agency: hospitals report longer discharge delays, added costs, and bed-availability pressure when a discharge-ready patient cannot be placed with a home health agency promptly; patients can lose access to the early recovery window in which home-based rehabilitation and skilled nursing intervention tends to be most effective; families are sometimes left coordinating informal care while a suitable agency is located; and health plans managing value-based post-acute care arrangements report difficulty coordinating timely placements as part of those programs.

Reporting on this dynamic in the home health trade press describes referral rejection as a problem with consequences distributed unevenly across the health care system: hospitals absorb longer discharge delays, rising costs, and reduced bed availability when a discharge-ready patient cannot promptly be placed with a home health agency; patients risk losing access to the early recovery window during which home-based rehabilitation and skilled nursing intervention is generally considered most effective; families are sometimes left coordinating informal, unpaid caregiving arrangements while a suitable agency is identified; and health plans managing post-acute care under value-based payment arrangements report difficulty meeting coordination and timeliness benchmarks when referrals stall. Those downstream effects are the backdrop against which CMS introduced the acceptance-to-service standard, even though the standard itself, as finalized, does not directly regulate rejection rates or placement timelines.

It is also worth noting, in the interest of a balanced account, that the acceptance-to-service requirement drew some skepticism from industry observers when it was first proposed and finalized as part of the broader CY 2025 HH PPS rule. Some commenters and industry analysts have argued that requiring agencies to have a documented, consistent acceptance policy addresses process transparency but does not, on its own, address the underlying capacity and staffing shortages driving referral rejections in the first place, nor does it set any standard for how quickly an agency must initiate care once a referral is accepted. From that vantage point, a home health agency facing a genuine staffing shortfall can comply fully with the acceptance-to-service requirement — by documenting a consistent, capacity-based policy — while still declining a comparable volume of referrals it previously would have declined, simply because the underlying capacity constraint driving those declines has not changed. CMS's own framing of the requirement in this memo is more modest than a capacity-expansion measure: it describes the goal as reducing the delay and mismatch between referral and acceptance decisions through more consistent, transparent processes, rather than as a mechanism to increase the overall volume of referrals any given agency can accept.

Timeline: What Takes Effect When

November 1, 2024 — CMS issues the Calendar Year 2025 Home Health Prospective Payment System final rule, published in the Federal Register on November 7, 2024 (89 FR 88354), which adds the acceptance-to-service standard to the HHA Conditions of Participation at 42 CFR § 484.105(i).

January 1, 2025 — The acceptance-to-service policy requirement and the related public service-information requirement become legally effective for all Medicare-certified home health agencies.

January 13, 2018 — The dividing line CMS uses to determine which HHA administrator qualification standard applies: individuals already serving as administrator before this date may continue under the original §484.115(a)(1) standard; those hired on or after this date must meet the newer §484.115(a)(2) standard. This date was established by a 2017 final rule and is unchanged by this memo.

July 15, 2026 — CMS issues QSO-26-13-HHA, adding survey citation tags G990 and G992 to State Operations Manual Appendix B for the acceptance-to-service and public-information requirements, and clarifying existing guidance under tag G1052 for HHA administrator qualifications. The memo is effective immediately, and CMS has directed that it be communicated to all appropriate state survey staff immediately.

Shortly after July 15, 2026 — The revisions to State Operations Manual Appendix B, initially distributed as an advance copy attached to this memo, are expected to be incorporated into the SOM's official online version.

What This Means for Home Health Agency Operators

For HHA administrators and compliance staff, the first and most direct action item is straightforward: confirm that a written acceptance-to-service policy actually exists, that it explicitly addresses all four required elements — anticipated patient needs, case load and case mix, staffing levels, and staff skills and competencies — and that it has been reviewed within the past year. Agencies that have been managing referral acceptance informally, through individual intake staff judgment rather than a documented, consistently applied policy, should treat this as the area of highest compliance risk under the new G990 tag, since the standard specifically requires consistency of application, not merely the existence of a policy document that sits unused.

Operators should also review their public-facing service information — whether on their own website, marketing materials, or as reflected on Care Compare — against what their agency is actually staffed and equipped to provide today, given the G992 requirement to review that information whenever services change and at least annually regardless. Agencies anticipating any service gap of roughly three to six months or longer, whether from a staffing departure, an extended leave of absence, or a deliberate service-line pause, should treat that as a trigger for updating public information promptly, and should document the date any correction request was submitted through PECOS and to their OASIS Education or Automation Coordinator, given the survey safe harbor tied specifically to evidence of a timely correction request rather than to how quickly Care Compare itself reflects the change.

HHAs should also review their administrator's qualifications against the correct standard for that individual's hire or role-assumption date relative to January 13, 2018, using the newly clarified guidance under G1052, to confirm there is no ambiguity in the agency's own compliance file about which qualification track applies. Finally, because the acceptance-to-service policy is explicitly distinct from the individualized plan of care under §484.60, compliance and clinical leadership should ensure staff understand the two as separate processes addressing separate points in the patient relationship — the initial accept-or-decline decision, and the clinical care planning that follows acceptance — so that documentation and staff training reflect that distinction clearly ahead of any future survey.

Multi-location HHA organizations and larger home health chains should also consider whether their acceptance-to-service policy needs to be evaluated on a location-by-location basis rather than as a single, organization-wide document, since staffing levels, case load and case mix, and staff skills and competencies can all vary meaningfully between an organization's individual branch locations even when they operate under shared corporate policies and a shared brand. A single, generic acceptance-to-service policy that does not reflect real differences in local staffing and capacity across an organization's various service locations may not satisfy the requirement's emphasis on the policy reflecting the HHA's actual, current capacity to provide care at the specific location fielding a given referral.

What This Means for Hospitals, Discharge Planners, and Referral Sources

For hospital discharge planning teams, physician offices, and other entities that refer patients to home health care, the practical effect of this requirement is intended to be greater consistency and transparency on the front end of the referral process. In principle, an HHA operating under a properly implemented acceptance-to-service policy should be able to give referral sources a clearer, more predictable sense of whether a given patient is likely to be a good fit before a referral is submitted, based on publicly available and consistently applied criteria, rather than referral sources learning only after submission — sometimes after a delay — that an agency cannot accommodate a particular patient's needs.

That said, referral sources should understand the limits of what this requirement actually guarantees. It does not require an HHA to accept any minimum share of referrals, nor does it set a required timeframe for initiating care once a referral is accepted; it requires only that the agency's decision-making process be documented and applied consistently. Hospitals and other referral sources managing ongoing discharge-delay or referral-rejection challenges with a given HHA may find this requirement useful as a basis for requesting to review that agency's acceptance-to-service criteria directly — since HHAs are expected to work with referral sources to educate them on the agency's policy and the services it offers, specifically with the stated goal of minimizing communication gaps between referral sources and the HHA — but should not expect the requirement alone to resolve capacity-driven placement delays tied to broader home health workforce shortages.

What This Means for Patients and Families

For patients and family caregivers navigating a hospital discharge, a physician referral, or another point of entry into home health care, this requirement is unlikely to be directly visible in the way, for example, a new consumer-facing icon on a comparison website would be. Its intended effect is more structural: a more consistent, transparent process behind the scenes that CMS argues should reduce delays between eligibility for home health care and the actual start of that care, and that should make an HHA's publicly available information about the services it offers — and any current limitations on those services — more reliable when patients or family members are comparing options.

Families evaluating home health agencies can reasonably expect the service information they find on Care Compare, an agency's website, or its printed materials to reflect a review conducted within roughly the past year at the latest, and to have been updated more recently if the agency has undergone any specific service change in the interim, keeping in mind CMS's own acknowledgment that updates to certain provider-level information can take up to six months to actually appear on Care Compare after an agency requests a correction.

Patients and caregivers who are declined by a home health agency, or who are told an agency cannot accommodate a specific service need, may find it useful to know that agencies are now expected to be evaluating referrals against a documented, written policy rather than an informal or inconsistent internal process — meaning families and referring clinicians have a more concrete basis to ask an agency directly what specific capacity or staffing gap led to a decline, and whether that gap is likely to be resolved on any particular timeline. That said, families should not expect this requirement to guarantee a faster placement in a tight local home health market; it governs the consistency and transparency of the decision-making process, not the underlying availability of home health capacity in a given community.

The Bigger Picture

Taken as a whole, QSO-26-13-HHA is a survey-enforcement memo rather than a new policy in its own right — the underlying acceptance-to-service and public-transparency requirements were established more than a year earlier, in the CY 2025 HH PPS final rule, and have technically applied to every Medicare-certified home health agency since January 1, 2025. What this memo adds is the interpretive infrastructure CMS's state survey partners need to actually evaluate and enforce that standard: two new citation tags, detailed interpretive guidance explaining exactly what surveyors should look for, and a practical safe harbor addressing the reality that CMS's own public reporting systems do not update in real time.

Read alongside the broader national conversation about home health referral rejections and post-acute care bottlenecks, the requirement represents a targeted, process-oriented intervention rather than a capacity-expanding one: it asks agencies to be consistent and transparent about how they decide whom to accept, without directly addressing the underlying staffing shortages that drive many acceptance decisions in the first place. For an industry sector serving a growing and aging Medicare population against a persistent home health workforce shortage, whether consistency and transparency requirements meaningfully reduce placement delays — as opposed to simply documenting, more clearly, the same capacity constraints that already existed — is likely to remain an open question as State Survey Agencies begin citing compliance under the new G990 and G992 tags going forward.

The administrator qualification clarification bundled into the same memo, though unrelated in substance, illustrates a separate and more routine function these periodic QSO memos serve: resolving accumulated interpretive ambiguity in longstanding requirements before it produces inconsistent survey findings across different states or regions. Neither change in this memo rewrites the underlying Conditions of Participation; both are aimed at giving State Survey Agencies, and the roughly 12,089 home health agencies they oversee, a clearer, shared, and more current reference point for requirements that, in one case, are brand new, and in the other, have quietly applied since 2018.

Frequently Asked Questions

What is QSO-26-13-HHA? QSO-26-13-HHA is a CMS memorandum issued July 15, 2026, to State Survey Agency Directors, providing formal survey guidance — including two new citation tags — for the home health agency "acceptance-to-service" Condition of Participation requirement, plus a separate clarification of HHA administrator qualification rules.

What is the acceptance-to-service policy requirement? It requires every Medicare-certified home health agency to develop, implement, and review at least annually a written policy, applied consistently to every prospective patient referral, addressing the patient's anticipated needs, the agency's case load and case mix, its staffing levels, and its staff's skills and competencies.

When did the acceptance-to-service requirement take effect? January 1, 2025, under the Calendar Year 2025 Home Health Prospective Payment System final rule (89 FR 88354). This July 2026 memo adds the formal survey guidance and citation tags needed to enforce it, effective immediately.

What are G990 and G992? They are new tags added to State Operations Manual Appendix B. G990 covers the acceptance-to-service policy itself. G992 covers the related requirement that HHAs make accurate service information publicly available and review it whenever services change, but no less than annually.

What counts as a "change" in services under G992? Adding, discontinuing, temporarily pausing, or restricting a service — including situations like a staff member's extended leave of absence or the addition of a new contracted employee providing a service the agency didn't previously offer. CMS expects agencies to update public information if they anticipate a service gap of roughly three to six months or longer.

Can an HHA be cited if Care Compare shows outdated information? Not automatically. Because updates can take up to six months to appear on Care Compare after being requested, surveyors are instructed not to cite an HHA for a Care Compare discrepancy if the agency can show it already requested the correction through PECOS and its OASIS Education or Automation Coordinator.

How is the acceptance-to-service policy different from a patient's plan of care? The acceptance-to-service policy is an HHA-level document governing whether the agency accepts a referral in the first place. The individualized plan of care, under a separate requirement at 42 CFR § 484.60, is the clinical care plan developed for a specific patient after that patient has already been accepted for services.

What changed about HHA administrator qualifications? Nothing substantively — this memo clarifies existing guidance, not a new rule. Individuals who began serving as administrator before January 13, 2018 may continue under the original qualification standard (physician, RN, or relevant training and experience). Individuals hired into the role on or after that date must meet a more specific standard requiring a professional license, RN status, or an undergraduate degree, plus relevant supervisory or administrative experience.

Does this requirement guarantee faster home health placement after a hospital discharge? Not directly. It requires HHAs to have a documented, consistently applied acceptance process, but it does not set a minimum referral-acceptance rate or a required timeframe for starting care, and does not directly address the staffing shortages that drive many referral rejections.

Who should hospitals and discharge planners contact with questions about this guidance? CMS has designated HHAsurveyprotocols@cms.hhs.gov for questions relating to this memorandum.

How many home health agencies does this requirement affect? Roughly 12,089 Medicare-certified home health agencies operate nationwide under recent CMS counts, and every one of them has been subject to the acceptance-to-service and public-information requirements since January 1, 2025.

What is a G-tag, and why does it matter that CMS added new ones? A G-tag is the alphanumeric identifier CMS's State Operations Manual Appendix B uses to label a specific home health regulatory standard, paired with interpretive guidance surveyors use to evaluate compliance. Without a dedicated tag, surveyors lacked a standardized way to cite and document noncompliance with the acceptance-to-service and public-information requirements, even though HHAs were already legally bound by both. G990 and G992 close that gap.

Does the acceptance-to-service policy require an HHA to accept more referrals? No. It requires the agency to make accept-or-decline decisions using a documented, consistently applied policy tied to its actual capacity, not to accept any particular share or volume of referrals. Some industry commenters have noted this distinction, arguing the requirement addresses process transparency rather than the underlying staffing shortages driving many referral declines.

What happens if an HHA is cited for noncompliance under G990 or G992? As with other Conditions of Participation findings, a cited deficiency generally requires the HHA to submit and implement an acceptable plan of correction, with the specific consequences depending on the severity and pattern of noncompliance identified, consistent with CMS's standard survey and enforcement framework for home health agencies.

This article is based on CMS memorandum QSO-26-13-HHA, "Acceptance-to-Service Requirement for Home Health Agencies and updated Guidance," issued July 15, 2026, by the Quality, Safety & Oversight Group at the Centers for Medicare & Medicaid Services, including its attached Summary of Changes to SOM Appendix B and advance copy of the updated surveyor guidance. For the complete memorandum and current State Operations Manual guidance, home health agencies and other stakeholders should consult CMS's official guidance at cms.gov.

Reporting: HealthBridge US Policy Desk