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Home Health Agencies Received Timely Surveys and Corrected Deficiencies as Required


Over the last decade, the use of home health services increased significantly and Medicare payments to home health agencies (HHA) more than doubled. To ensure that HHAs comply with Federal requirements, the Centers for Medicare & Medicaid Services (CMS) contracts with each State survey agency (State agency) and three accreditation organizations to conduct initial certification surveys of HHAs, recertification surveys, and complaint investigations. CMS also monitors the performance of accreditation organizations by contracting with State agencies to perform "look-behind" surveys of HHAs recently surveyed by accreditation organizations. CMS compares an accreditation organization's survey of an individual HHA with a State agency's subsequent survey of the same HHA, and then uses that information in aggregate to evaluate the accreditation organization's overall survey performance. A 2008 study by the Office of Inspector General (OIG) found that many HHAs had the same deficiencies cited during multiple recertification surveys and CMS rarely used the only sanction available-termination-to address HHA noncompliance.


Using CMS data for Federal fiscal years 2010 and 2011, we identified the extent to which State agencies and accreditation organizations conducted timely recertification surveys of HHAs. We also identified the extent to which HHAs received deficiency citations, corrected deficiencies, or had complaints lodged against them. Additionally, we determined the extent to which CMS used look-behind surveys to assess the performance of accreditation organizations and State agencies.


State agencies and accreditation organizations conducted recertification surveys for nearly all HHAs within the required 36-month timeframe and cited 12 percent of HHAs with "condition" level deficiencies, the most serious type of deficiency. Ninety-three percent of these HHAs corrected their condition-level deficiencies within the required 90-day timeframe; the remaining 7 percent corrected the deficiencies late or left Medicare. Fifteen percent of HHAs had complaints lodged against them; surveyors conducted complaint investigation surveys for nearly all of these HHAs and cited 7 percent of them with condition level deficiencies. With few exceptions, HHAs corrected all condition-level deficiencies cited during complaint surveys. State agencies exceeded the required number of look-behind surveys for oversight of accreditation organizations. CMS rarely conducted look-behind surveys for oversight of State agencies' surveys of HHAs; such look-behind surveys are not required by Federal regulation.


We recommend that CMS analyze survey data to determine whether it should routinely conduct look-behind surveys for oversight of State agencies, which conduct most HHA recertification surveys. CMS concurred with our recommendation and stated that its central office will work with the CMS regional offices to identify State agencies with the greatest need for look-behind surveys.