The Centers for Medicare & Medicaid Services (CMS) has released new survey guidance clarifying how Medicare-certified home health agencies will be evaluated for compliance with the Acceptance-to-Service requirements added to the Home Health Conditions of Participation (CoPs) earlier this year.

Issued through Quality, Safety & Oversight (QSO) Memorandum 26-13-HHA on July 15, 2026, the guidance provides surveyors and providers with additional clarification regarding the patient acceptance process, public reporting of agency services, and annual review requirements. While the underlying regulation became effective January 1, 2025, the new memorandum explains how CMS expects agencies to implement and maintain these policies during surveys.

Acceptance-to-Service Policy Required

Under the updated CoPs, every Medicare-certified home health agency must develop, implement, and annually review a written Acceptance-to-Service Policy that is applied consistently to every prospective patient referred for care.

CMS emphasizes that the policy should help agencies determine whether they have the capacity to safely and appropriately meet a patient's anticipated needs while reducing unnecessary delays in initiating home health services.

At a minimum, the policy must evaluate four factors:

• The anticipated needs of the referred prospective patient
• The agency's current caseload and case mix
• Available staffing levels
• The skills and competencies of agency staff 

CMS notes that agencies may tailor their policies to address additional operational considerations, including referral challenges or procedural delays commonly encountered during the admission process.

Referral Sources Should Understand Agency Capabilities

The guidance places responsibility on home health agencies to educate hospitals, physicians, discharge planners, and other referral sources about both their acceptance-to-service policies and the services they offer.

According to CMS, improving communication between referral sources and providers should help reduce inappropriate referrals and better match patients with agencies capable of meeting their clinical needs. CMS also recognizes that complete clinical information may not always be available at the time of referral. However, information such as the patient's diagnosis, recent hospitalization, and physician orders should generally provide enough information for an agency to determine whether it can safely accept the referral.

Agencies Must Publicly Disclose Service Limitations

In addition to maintaining an acceptance-to-service policy, home health agencies must make accurate information publicly available regarding:

• Services they provide
• Specialty services offered
• Limitations on service frequency
• Limitations on service duration
• Any restrictions affecting service availability

CMS does not prescribe a single method for making this information available. Agencies may satisfy the requirement through resources such as:

• CMS Care Compare
• Agency websites
• Printed brochures
• Other publicly accessible materials 

Public Information Must Be Updated

The memorandum also clarifies that agencies must review publicly available service information whenever services change and at least annually.

CMS considers a "change in service" to include circumstances such as:

• Adding a new clinical service
• Discontinuing a service
• Temporarily suspending a service
• Restricting a service because of staffing shortages or extended employee leave

The agency expects providers to update public-facing information when a service is anticipated to be unavailable for three to six months. Examples include extended medical leave, maternity leave, or the addition of new contracted clinicians that expand available services.

Review Your Care Compare Information

CMS reminds providers that information displayed on Care Compare originates from data collected during surveys and maintained through the CMS-1572 Survey Report Form, Provider Enrollment, Chain, and Ownership System (PECOS), and the Internet Quality Improvement and Evaluation System (iQIES) system.

Providers should verify that their service information is current in PECOS and, when updates are needed, work with their Outcome and Assessment Information Set (OASIS) Education Coordinator or OASIS Automation Coordinator to ensure the information in iQIES is corrected.

CMS also notes that updates to Care Compare are not immediate and may take up to six months to appear publicly. During surveys, agencies that can demonstrate they requested corrections will generally not be cited solely because Care Compare has not yet been updated.

Additional Administrator Clarification

Although unrelated to the new acceptance-to-service requirements, CMS also clarified existing administrator qualification standards.

The memorandum reiterates that individuals serving as a home health administrator before January 13, 2018, remain subject to the qualifications established under the previous regulatory standard, while administrators hired on or after January 13, 2018, must meet the qualifications adopted under the revised CoPs. CMS notes this clarification is intended to address a question frequently raised by providers and surveyors rather than announce a new requirement.  

What Florida Home Health Agencies Should Do Now

HCAF encourages Medicare-certified home health agencies to review their acceptance-to-service policies to ensure they fully address the four required evaluation criteria and are applied consistently to every referral. Agencies should also verify that publicly available descriptions of their services accurately reflect current capabilities and any temporary or ongoing service limitations.

Providers should ensure internal policies are reviewed annually, educate referral sources regarding their acceptance criteria, and periodically confirm that information displayed on Care Compare and other public-facing platforms remains accurate.

As surveyors begin using the updated interpretive guidance, agencies should expect greater scrutiny of both their written acceptance-to-service policies and the accuracy of publicly available information describing their services.