Types of Hospice Surveys: What Every Provider Must Know to Stay Compliant

Discover the key types of hospice surveys—including initial certification, recertification, and complaint investigations—and learn where your agency stands in the eyes of Medicare and accrediting bodies.

Section 1: Understanding the Initial Medicare Certification Survey for Hospice Providers

Before a hospice agency can officially join the Medicare program, it must pass a rigorous Initial Certification Survey conducted by either the State Agency (SA) or a CMS-approved Accrediting Organization (AO) with “deeming authority.” But before that happens, your hospice must formally request this survey in writing.

To be eligible for this survey, your hospice must check off several important boxes:

• Medicare Enrollment Verified: Your hospice must complete Form CMS-855A and receive confirmation from the designated Medicare Administrative Contractor (MAC).

• Fully Operational: Your agency must be actively providing services at the time of the survey.

• Minimum Patient Requirements: You must have cared for at least five patients (they don’t have to be Medicare beneficiaries), with three currently receiving services at the time of the survey.

• Special Rule for Underserved Areas: If your hospice is located in a CMS-designated medically underserved region, the patient requirement can be reduced to two—one of whom must be receiving care during the survey.

• Full Scope of Services: Even if your active patients don’t require all hospice services, your agency must demonstrate readiness and the ability to provide the complete range of required care.

• Operational Readiness: You must be able to prove that every part of your operations meets Medicare’s Conditions of Participation (CoPs)

• Important Note: Your official Medicare certification date will only be recognized from the moment your hospice demonstrates full compliance with all federal requirements—no exceptions (per 42 CFR § 489.13).

Section 2: Standard (Recertification) Survey

Hospice providers are required to undergo a standard survey every three years, which is carried out by either the State Agency (SA) or a CMS-approved accrediting organization (AO). This process ensures the hospice continues to meet all federal requirements for Medicare participation.

When a hospice operates multiple service locations, surveyors are expected to include those sites in the review—especially if any of the alternate locations serve more patients than the primary location tied to the CMS Certification Number (CCN). Whenever feasible, surveyors should visit as many of these additional sites as possible.

Importantly, any compliance issues found at one or more of these locations are considered deficiencies for the entire hospice organization, not just the site where the issues occurred. This includes the main hospice and all affiliated locations under the same CCN.

Section 3: Complaint Investigation Survey

Investigating and resolving complaints is a vital part of maintaining hospice certification. A complaint survey is triggered when there are credible reports or serious allegations suggesting that the hospice may not be in compliance with federal requirements.

These surveys are designed to thoroughly examine the specific issues raised in the complaint.

If, during the course of the investigation, surveyors identify one or more condition-level deficiencies, they may choose to expand the scope of the review to include additional or all applicable Medicare Conditions of Participation (CoPs) to ensure a comprehensive assessment.

Section 4: Post-Survey Revisit (Follow-Up Survey)

If a hospice is found to have deficiencies during a survey, the State Agency (SA) may conduct a follow-up survey, also known as a post-survey revisit, to assess whether the hospice has successfully addressed and corrected the cited issues.

In cases where condition-level deficiencies are identified, a follow-up visit must be conducted in person to verify full compliance before the hospice can regain good standing.

Section 5: Change in Ownership (CHOW) Survey

When a hospice undergoes a Change in Ownership (CHOW) and submits notification to the Medicare Administrative Contractor (MAC), it triggers a review process. The CMS Location and/or the State Agency (SA) will determine whether a desk review or an on-site survey—or both—are needed before officially approving the ownership transition.

Section 6: Validation Survey for Deemed Hospices

Validation surveys are used as a way for CMS to oversee the performance of accrediting organizations (AOs) that have been granted deeming authority. These surveys are carried out by State Agencies (SAs), but only under the direction of the designated CMS Location.

CMS Headquarters is responsible for selecting which deemed-status hospices will undergo a validation survey. Once the selection is made, CMS notifies the appropriate regional CMS Location, which in turn instructs the SA to conduct the on-site validation review.

HealthBridge is here to support your hospice through every type of survey and post-survey requirement. Whether you're facing an Initial Certification, Standard (Recertification), Complaint Investigation, Validation, or Change in Ownership survey, our team provides expert guidance every step of the way.

We also specialize in post-survey activities, including managing Immediate Jeopardy situations, developing and submitting effective Plans of Correction, and working directly with the State Survey Agency or accrediting bodies such as The Joint Commission, CHAP, or ACHC.

Contact us today to learn how we deliver turnkey compliance solutions that help your agency pass surveys with confidence and remain fully compliant.