CMS Home Health Survey Checklist: What to Have Ready

1. Personnel files should be complete and easy to retrieve

Build a repeatable personnel-file review before survey activity. For each active employee, make sure the agency can quickly produce evidence supporting qualifications, required training, competency documentation, and other records required by the role, your policies, and applicable state rules.

CMS deficiency records show agencies can be cited when sampled employee files do not demonstrate that personnel are qualified or when required documentation is incomplete.

2. HHA competency documentation needs to show more than a checkbox

For home health aides, review the competency-evaluation requirements in 42 CFR §484.80(c). CMS survey findings have cited agencies when competency requirements were not completed or when the documentation did not demonstrate that required elements were evaluated.

Keep the evaluator, date, evaluated skill areas, outcome, and supporting documentation together so the record tells a clear story.

3. Verify annual in-service training and the evidence behind it

42 CFR §484.80(d) requires at least 12 hours of in-service training during each 12-month period for home health aides and requires the HHA to maintain documentation showing the requirement was met.

Do not rely on a total-hours spreadsheet alone. Be ready to show dates, topics, hours, completion evidence, and the records your agency uses to demonstrate compliance.

4. Make sampled clinical records easy to follow

Surveyors evaluate agency performance and practices, not just policy language. Review whether current plans of care, orders, visit documentation, aide instructions, signatures, and related records can be located and understood without reconstructing the chart during the survey.

5. Test your evidence-retrieval process before the survey

Run a mock request: choose a few employees and patients, then time how long it takes to produce the requested evidence. Track missing items to closure. A readiness process should identify gaps before a surveyor does.