Transferring ownership or changing the licensed location of a Medicare-certified home health agency is a highly regulated process with multiple federal, state, and accreditation requirements. Whether your agency is completing a Change of Ownership (CHOW), a Change in Information (CHOW Non-Ownership), or a relocation under CDPH approval, the steps must be followed precisely to avoid interruptions in operations, delays in Medicare billing privileges, or even involuntary termination from the Medicare program.
This guide outlines the essential compliance considerations, required documents, timelines, and key pitfalls agencies must avoid before pursuing ownership transfers or location changes.
1. Understanding CHOW vs. CHOW Non-Ownership (Change of Information)
Before beginning any transition, it is essential to determine which category your agency falls into. CMS and state licensing agencies define these differently:
1.1. Change of Ownership (CHOW)
A CHOW occurs when the governing body of the agency changes, such as:
Sale of the agency to a new owner
Transfer of majority shares (usually 50% or more)
Merger with another organization
Addition or removal of partners where control changes
When a CHOW occurs, CMS requires:
A full CMS-855A CHOW application
Assignment of Medicare Number to new ownership
Confirmation that the agency remains operational with no service interruption
Updated CHOW documentation for the state licensing body (e.g., CDPH in California)
A CHOW can temporarily freeze or delay billing privileges, and errors in the process can lead to deactivation.
1.2. Change of Information (Ownership Structure Only)
This includes internal changes that do not alter controlling ownership, such as:
Adding officers (CEO, CFO, directors)
Transferring minority shares
Updating board members
In these cases, a full CHOW is not required, but:
The CMS 855A still must be filed for ownership updates
CDPH must receive updated information
The agency must notify accrediting bodies (ACHC/CHAP/JCAHO)
Updated organizational charts must be submitted
Misclassification of these two categories is one of the top causes of CMS application delays.
2. Requirements for a Change of Location (COL)
A Change of Location is required when the agency:
Moves its primary office
Expands or downsizes to a new physical space
Relocates to a new county or service region
Changes the geographic service area (GSA) or branch structure
2.1. CDPH Requirements for California Agencies
California agencies must submit:
CDPH Application for Change of Location
Floorplan of the new office
Lease agreement
Updated policies and procedures reflecting new address
Proof of the new office meeting operational requirements (staffing, storage, privacy, records management)
For some relocations, CDPH may conduct a site survey.
2.2. CMS Requirements for Medicare-Certified Agencies
CMS requires that the new location:
Maintains compliance with all Medicare CoPs
Has operational systems in place upon relocation
Has clinical staff available within the new geographic radius
Maintains patient services without interruption
A relocation triggers updates to:
Medicare may conduct an unannounced validation survey after relocation.
3. Compliance Requirements You Must Prepare Before Any Transfer
3.1. Operational Readiness Documentation
Before relocating or transferring ownership, your agency must ensure:
Updated business licenses
Updated organizational structure
All policies reflect new ownership/location
Updated emergency preparedness plan
Updated Quality Assurance/Performance Improvement (QAPI) documentation
HR files and credentials for new officers
New address reflected in patient rights forms and admission packets
Medicare auditors often request proof that operations remained unchanged throughout the transition, so documentation is crucial.
3.2. Clinical Compliance Requirements
Even during a transfer or relocation, agencies must maintain continuous compliance with:
Comprehensive assessments under §484.55
Plan of Care requirements under §484.60
Coordination of services
60-day OASIS timeframes
Home health aide supervision
Skilled documentation standards
Any lapse in compliance during ownership transfer can result in survey citations.
4. Key Documents Required (Federal, State, and Accreditation)
The following documents are typically required for ownership transfers or relocations:
4.1. CMS Documents
CMS 855A application
CMS 855B (if applicable)
CMS 588 EFT form
Organizational documents (Articles of Incorporation, bylaws, EIN)
Ownership disclosure statements
Lease or sublease agreements
Staff roster
Updated governing body meeting minutes
Updated Board Resolution approving CHOW
4.2. State Licensing Documents (CDPH for California)
CDPH Licensing Change Packet
Proof of legal name (Articles, Statement of Information)
Lease agreement for new location
Floor plan with office layout
Hours of operation
Updated ownership list with percentages
Updated policies & procedures
4.3. Accreditation Bodies (ACHC/CHAP/JCAHO)
30–60 day notice of change
Updated organizational chart
Updated leadership resumes
Updated address on all forms
Proof of operational compliance at new site
May require a revisit or survey
Failure to notify your accrediting body is one of the leading causes of suspended accreditation after a CHOW.
5. Timeline Expectations: How Long Does the Process Take?
The timeline varies by state, but the approximate timeframes are:
CHOW (Ownership Transfer): 4–8 months
Change of Location (COL): 2–6 months
CMS PECOS Processing: 30–90 days
Accreditation Notice Requirements: 30–60 days before the change
CDPH Licensing Approval: 60–120 days
Survey Validation (if triggered): within 90 days
Delays occur commonly when:
Organizational documents do not match CMS filings
CDPH receives incomplete packets
Accreditation bodies are not notified
The new location is not fully furnished and operational
There are missing signatures or outdated policies
6. Common Mistakes Agencies Make (and How to Avoid Them)
6.1. Not Notifying Medicare in Advance
CMS requires updates before changes occur. Filing afterward creates major delays.
6.2. Using a Virtual Office
CMS and CDPH do NOT allow relocations to virtual spaces, shared spaces without walls, or spaces lacking clinical storage capabilities.
6.3. Incomplete Organizational Documents
Many agencies fail to update:
6.4. Not Updating Policies and Procedures
A new office address and new officers must be reflected in:
6.5. Not Preparing the Office for a Survey
Relocation can trigger surveys, so the office must be ready with:
Clinical binders
Infection control supplies
HR files
Equipment calibration logs
Secure PHI storage
Private intake/assessment space
7. How to Prepare Your Agency for a Successful Ownership Transfer or Relocation
7.1. Conduct a Pre-CHOW Compliance Review
This should include:
HR file audit
Clinical chart audit
QAPI review
Governing body documents audit
Emergency preparedness drill review
Review of physician orders and signatures
7.2. Prepare the New Owners (For CHOW)
New owners must be trained in:
CMS expects that the agency remains fully compliant regardless of ownership.
7.3. Prepare the New Office (For COL)
Your new office must include:
7.4. Update All Required Systems
This includes:
NPI Registry
PECOS
IRS
Accreditation portal
State licensing
Medicare MAC
Pharmacy vendors
DME providers
Lab contracts
Insurance payers
EDI/ERA enrollments
Missing even one vendor update can disrupt patient care or billing.
8. Post-Approval Requirements
Even after approval, agencies must:
Retain documentation of the transition for 7 years
Update all admission packets
Ensure accurate Medicare claims submission
Maintain survey readiness
Maintain proper notices to patients regarding ownership changes
CMS may revisit to verify compliance after a major organizational change.
Conclusion
Transferring ownership or relocating a home health or hospice agency involves far more than filing forms. It requires careful coordination between Medicare, state licensing bodies, accreditation organizations, and internal agency operations. Agencies that fail to plan properly often face major delays, financial interruptions, or survey deficiencies.
To ensure a smooth and compliant transition—without risking your Medicare billing privileges—expert guidance is essential.
Need Help With CHOW, Change of Location, CDPH Filings, or Medicare Applications?
HealthBridge provides full-service consulting and management solutions for home health, hospice, and home care agencies nationwide.
We assist with:
CHOW & ownership transfers
Change of location filings
CDPH licensing
CMS 855A/PECOS updates
Accreditation notifications
Survey readiness
QAPI, policies, and compliance documentation
Our team ensures your transition is smooth, compliant, and free of survey risk.
References:
Medicare Provider Enrollment, Chain, and Ownership System (PECOS).
https://pecos.cms.hhs.gov
CMS Form 855A – Medicare Enrollment Application for Institutional Providers.
https://www.cms.gov/medicare/cms-forms/cms-forms/downloads/cms855a.pdf
CMS State Operations Manual, Appendix B – Home Health Agency Interpretive Guidelines.
https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/som107ap_b_hha.pdf
