The Centers for Medicare and Medicaid Services (CMS) has issued updated survey guidance for home health agencies regarding home health acceptance-to-service standards, a requirement that became effective in January 2025. According to a CMS memo, agencies must now maintain a formal policy to determine if they have the capacity and skill sets necessary to accept a referred patient, while ensuring their service limitations are transparently available to the public.
This guidance clarifies the Home Health Agency Conditions of Participation, focusing on the intersection of agency capacity and patient needs. By requiring agencies to document their caseload, staffing levels, and specific competencies, CMS aims to reduce communication gaps between referral sources and providers. The updated standards mandate that agencies publish any limitations on specialty services, duration, or frequency of care to ensure patients and providers have accurate expectations before the referral process begins.
The shift toward formalized acceptance policies is designed to minimize communication gaps that occur when an agency accepts a referral only to later determine they cannot provide the required specialty service. According to the Centers for Medicare and Medicaid Services, the goal is to create a reasonable basis for determining if a prospective patient is appropriate for a specific agency’s current capabilities.
Four Mandatory Elements of Acceptance-to-Service Policies
CMS specifies that every home health agency (HHA) must develop and implement an acceptance-to-service policy containing four core components. These elements allow an agency to assess its internal capacity against the requirements of a referred patient. According to the CMS memo, these required elements are:
- Information regarding the anticipated needs of the referred prospective patient.
- The agency’s caseload and case mix.
- Staffing levels.
- The specific skills and competencies of the staff.
The agency stated in the memo that these four factors “inform a [home health agency’s] (HHA) assessment of its capacity and determine its suitability to meet the anticipated needs of the prospective patient referred for HHA services.” While CMS acknowledges that a patient’s full needs may not be known at the moment of referral, the agency expects providers to use a patient’s diagnosis, recent hospitalization (as appropriate), and medical provider orders to make an informed decision on acceptance.
CMS allows agencies to tailor these policies further to address additional concerns, procedural delays and challenges often experienced during the referral and acceptance process within these policies, provided the four mandatory elements remain the foundation of the policy.
Public Disclosure of Service Limitations and Offerings
A critical component of the new guidance is the requirement for agencies to make their service offerings and limitations public. CMS requires that this information include any restrictions on specialty services, as well as limitations on the frequency or duration of services provided. This ensures that the public and referring physicians are aware of what an agency can and cannot provide before a patient is referred.
CMS does not mandate a single format for these disclosures. According to the guidance, agencies may use several different channels to communicate their services, including:
- The CMS Care Compare website.
- Official agency websites.
- Printed brochures and informational materials.
To ensure this information remains current, CMS requires agencies to review their public-facing data at least annually. However, a more immediate update is required whenever an agency “changes a service.” The memo defines a change in service as formally adding, discontinuing, temporarily pausing, or restricting a service. CMS specifically expects agencies to update their public information if they anticipate a service will be unavailable for a period of three to six months.
The guidance provides concrete examples of such changes, noting that a service may be restricted if an employee takes an extended leave of absence for maternity or medical reasons, or if the agency adds a new contract employee, such as a speech-language pathologist, to expand their offerings.
Data Integration via iQIES and PECOS
The mechanism for updating these public records involves several federal databases. CMS obtains service information from the CMS-1572 survey report form, which is filled out by agency staff. This data is then entered into the iQIES database, which serves as the source for some CMS public reporting, including the CMS Care Compare website.
To ensure accuracy, CMS instructs home health agencies to first complete their information in the Provider Enrollment, Chain, and Ownership System (PECOS). Following the PECOS update, agencies must contact their OASIS Education Coordinator or OASIS Automation Coordinator to request that the corresponding data in iQIES be updated. This chain of reporting ensures that the information viewed by the public on federal portals matches the agency’s actual operational capacity.
For agencies seeking to verify their current public standing, the Medicare Care Compare tool is the primary portal where these service offerings are displayed to the global public and healthcare providers.