How to Expand Your Home Health Agency’s Geographical Service Area (GSA): A Step-by-Step Guide for CDPH and CMS

Expanding your Home Health Agency’s Geographical Service Area (GSA) is one of the most effective ways to increase patient volume, build referral partnerships, and reach underserved communities. However, expanding your GSA is a highly regulated process, requiring careful compliance with both the California Department of Public Health (CDPH) and the Centers for Medicare & Medicaid Services (CMS).

This step-by-step guide outlines everything your agency needs to successfully expand its service area while remaining fully compliant with Home Health Medicare Conditions of Participation (CoPs), California state licensing requirements, and operational readiness expectations.

Why Expanding Your GSA Matters

Expanding your home health GSA allows your agency to:

• Serve more patients across a larger geographic region

• Build relationships with more hospitals, SNFs, physicians, and ALFs

• Create redundancy in referral streams

• Improve agency revenue and stability

• Increase brand visibility across multiple counties

• Bring skilled care to underserved or rural populations

But because home health is governed by strict Medicare and CDPH regulations, expansion must be done methodically and legally—without disrupting care, compliance, or billing.

Understanding Regulatory Oversight

To expand your GSA, your agency must satisfy requirements from:

1. CDPH – Licensing Division

CDPH regulates home health agencies at the state level and requires notification and approval for changes to:

• Service areas

• Locations

• Ownership

• Governing body

• Essential personnel
  

2. CMS – Medicare Conditions of Participation (42 CFR §484)

CMS requires compliance with:

• Patient access standards

• Staffing capability

• Supervision requirements

• Emergency and transportation readiness

• Quality assurance/performance improvement (QAPI)

• Accurate documentation and episodic management
  Learn More.

Without meeting CoPs, Medicare may deny claims or restrict billing.

3. Accrediting Bodies (if applicable)

CHAP, ACHC, or Joint Commission also require internal documentation and policy updates reflecting the new service areas.

Before You Begin: Internal Readiness Checklist

Expanding too quickly—or expanding without required operational systems—can put your agency at risk. Before submitting anything to CDPH or CMS, ensure you meet the following:

✔ Adequate Staffing for the New Service Area

CMS requires that home health agencies have:

• Sufficient RNs for evaluation, OASIS assessments, supervision

• Therapists (PT/OT/ST)

• Medical social workers (MSW)

• Home health aides

• On-call capability 24/7

If you are expanding to another county, CMS expects local or accessible staffing, not staff driving excessive distances.

✔ Policies & Procedures Updated

Your P&P manual must reflect:

• New service zones

• Travel expectations

• Emergency response structures

• Availability requirements under §484.75 and §484.80
  Learn More.

✔ QAPI Program Capable of Measuring Additional Regions

CoPs require that QAPI include:

• Data-driven metrics

• Clinical indicators across all patient populations

• New service-area monitoring
  Learn More.

✔ Communication Systems & EMR Prepared

Your EMR and communication infrastructure must support:

• New zip codes

• Tracking clinician assignments

• Timely coordination of care

✔ Contracted Services are in Place (if needed)

If expanding far from your main office, CMS allows contracted:

• PT/OT/ST

• MSW

• Home health aides

But RN services should remain primarily directly employed.

Step-by-Step Guide to Expanding Your GSA

Step 1: Conduct a Regulatory Review

Before applying, review:

• CDPH Licensing Requirements for home health agencies

• CMS Conditions of Participation (42 CFR §484)

• Medicare Administrative Contractor (MAC) requirements for your region

• Accreditation standards (if accredited)

Regulatory compliance should guide your expansion—not the other way around.

Step 2: Determine Your New Counties or Zip Codes

A GSA expansion may include:

• A few additional zip codes

• Entire cities

• Entire counties (e.g., expanding from Los Angeles County into Orange County)

Important:
If you cross into a new county, CDPH may evaluate your staffing distribution and readiness more rigorously.

Step 3: Update Your Organizational Policies

Before notifying CDPH, revise:

• Service area policy

• Emergency preparedness plan (must include new counties)

• Staffing plan

• Transportation and response times

• Admission criteria

• Transfer and discharge policies

• Clinical supervision plans

These documents may be reviewed if CDPH asks for supporting materials.

Step 4: Notify CDPH via the Proper Licensing Process

CDPH requires a formal submission for a change in your GSA. Learn More.

Your CDPH packet should include:

• CDPH Change of Information Form

• Letter explaining the GSA expansion

• Updated policies and procedures

• Updated organizational chart (if adding additional management)

• Updated service area map

• Proof of staffing capability

• Any requested supporting documents

CDPH does not always conduct a survey, but they may request:

• Staff rosters

• Emergency preparedness evidence

• Call logs

• Staffing and scheduling systems

CDPH approval times vary depending on caseload and region.

Step 5: Update CMS Enrollment (if required)

If the expansion affects:

• Branch location

• Mobile units

• Staffing model

• Additional services

Then a CMS 855A update may be required. Learn More.

Most GSA expansions do not require a full CMS update unless:

• You are adding a branch

• You are adding a sub-unit

• You are relocating your primary office

• You are changing ownership or governance

However, you must ensure your CMS-approved service-area mapping aligns with your internal operations.

Step 6: Notify Your Accrediting Body (if accredited)

CHAP, ACHC, or Joint Commission may require:

• Updated service-area lists

• Updated policies

• Proof of staffing

• QAPI integration
  

They may verify readiness during:

• Annual surveys

• Interim self-studies

• Off-cycle documentation reviews

Step 7: Set Up Staffing & Operational Infrastructure

Once CDPH and CMS acknowledgment is received, implementation begins.

Staffing Readiness

• Hire clinicians who live in or near the new area

• Secure contracted therapy staff (if needed)

• Ensure availability of 24/7 on-call RN coverage

• Add backup staff through supplemental registries

Operational Programs

• Equip staff with company-issued phones/tablets

• Add zip codes to EMR

• Train staff on agency protocols

• Update emergency contact lists

• Configure scheduling and travel expectations

Orientation to New Regions

Educate all clinicians on local:

• Hospitals

• Skilled nursing facilities

• Discharge planners

• Assisted living facilities

• Community centers

• Referral partners

Building strong relationships accelerates growth in the new GSA.

Step 8: Build Referral Relationships in the New Area

Use your expanded GSA to create:

Hospital and SNF partnerships

• Case managers

• Hospital discharge planners

• Directors of nursing

• Physicians

Primary care & specialty clinics

• Geriatrics

• Cardiology

• Pulmonology

• Orthopedics

Community networks

• Senior centers

• Adult day health centers

• Home care agencies

• Social workers

Provide:

• Educational materials

• Service area maps

• Admission criteria

• Brochures

• Meet-and-greet sessions

Referral development is critical for making expansion profitable.

Step 9: Integrate the New Area into QAPI

CMS requires home health agencies to demonstrate quality oversight across all service areas, old and new. Learn More.

Update QAPI tracking:

• New county/city performance indicators

• Timeliness of care in new areas

• Missed visits

• Hospitalization rates

• Patient satisfaction in expanded areas

• OASIS accuracy

This ensures your agency meets §484.65 requirements.

Step 10: Ensure Emergency Preparedness Compliance

Your expansion must be reflected in:

• Hazard vulnerability analysis (HVA)

• Regional risk profiles

• County emergency resources

• Evacuation routes

• Communication systems

• Staff training

• Drill documentation
  Learn More.

CMS auditors and CDPH surveyors frequently review emergency preparedness for expanded service areas. Learn More.

Step 11: Begin Accepting Patients

Once all regulatory notifications, updates, staffing, and policies are in place, you can begin admitting patients in your new geographical areas.

Ensure:

• Intake staff are aware of new zip codes

• Website and marketing materials reflect the new regions

• Referral partners receive updated service maps

Common Mistakes to Avoid

Expanding without proper staffing

CMS may cite you under supervision or care standards.

Serving patients before CDPH approval

This can delay licensing changes and trigger compliance reviews.

Incomplete policy updates

Surveyors will expect your documentation to reflect the new GSA.

Failing to update emergency preparedness

This is one of the highest-cited deficiencies in home health.

Not training staff on new territories

Leads to missed visits, poor continuity of care, and patient dissatisfaction.

Conclusion

Expanding your home health agency’s GSA is a strategic move that strengthens your service capacity, market presence, and patient access. However, the process requires compliance with CDPH licensing rules, Medicare Conditions of Participation, operational standards, and strong internal readiness. With a structured approach, your agency can expand safely and successfully while maintaining the highest level of care.

If your agency needs support, guidance, or full-service management of GSA expansion, HealthBridge offers comprehensive consulting solutions including:

• CDPH licensing support

• CMS enrollment guidance

• Policy updates

• QAPI integration

• Staffing and operational evaluations

• Accrediting body preparation

• Complete expansion project management

HealthBridge ensures your expansion is compliant, smooth, and survey-ready from start to finish.