CMS Gives More Leeway in Home Health Citations

Home health agencies may breathe a sigh of relief thanks to the revision of a Home Health Agency Survey Protocol training item.

The Centers for Medicare and Medicaid Services (CMS) revised its training on the use of the HHA Survey Protocols, saying the phrase “consider citing the Condition” should indicate surveyors may consider citing the Condition, and not be taken as a prescriptive element of the guidance over surveyor judgement.

Previously, CMS training suggested that the phrase “consider citing the Condition” meant the surveyor should cite the Condition.


“[W]hen the phrase ‘consider citing the Condition’ is used, the intent is to ensure that the citation be carefully evaluated with respect to evidence and is not intended to preclude surveyor judgment,” CMS clarified in a letter dated Sept. 11. The new policy went into effect immediately upon publication of the letter.

When surveyors decide that expected outcomes have not been reached for the various standards/tags within a Condition, the HHA Survey Protocol offers HHA-specific guidelines for when surveyors may consider citing the actual Condition at issue.

Written by Mary Kate Nelson


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