We see the same thing happen to new home health and hospice agencies again and again. The state license arrives, everyone celebrates, and then the owner learns they still can’t bill Medicare. The missing piece is almost always accreditation.
Why a state license doesn’t get you paid by Medicare
Your state license lets you operate. To bill Medicare, a home health agency or hospice also has to be certified as meeting the federal Medicare Conditions of Participation. There are two ways to prove that:
- An initial certification survey by your state survey agency, or
- A survey by a CMS-approved accrediting organization that holds “deeming authority”. If one of these bodies accredits you, CMS treats you as meeting the Medicare requirements. That is what “deemed status” means.
Why accreditation is usually the faster route
State survey agencies put complaint investigations and recertifications of existing providers first. Initial surveys for brand-new agencies sit near the bottom of the list, and some states aren’t doing them at all right now. Texas is a good example: HHSC is not conducting initial Medicare certification surveys, so a new Texas agency that wants Medicare effectively needs an accreditor. In Florida, skilled-care home health agencies have to show accreditation from an AHCA-recognized body as part of state licensing anyway.
New agencies most often work with one of three accreditors:
- ACHC (Accreditation Commission for Health Care)
- CHAP (Community Health Accreditation Partner)
- The Joint Commission
All three hold CMS deeming authority for home health and hospice. They differ on price, survey style and how much support they give during preparation, so the right one depends on your services and your state.
The catch: it’s a survey, not a form
Accreditation isn’t paperwork you file and wait on. A surveyor visits, usually unannounced, and checks how your agency actually runs day to day. Expect them to look closely at:
- Your policies and procedures, and whether your staff really follow them
- Personnel files: licenses, competency checks, background checks, orientation and training records
- Your QAPI program (Quality Assessment and Performance Improvement), with real data and real improvement projects behind it
- Clinical records for the patients you’ve served, including plans of care and physician orders
- Emergency preparedness, infection control and patient rights
You also need patients before you can be surveyed. In Texas, for example, an agency seeking Medicare certification must have served at least 10 patients, with seven of them active on the day of the survey. So your systems have to be clean from your very first admission, not just in time for the surveyor’s visit.
Where new agencies lose months
- Starting accreditation prep after the license arrives. Policies, QAPI and complete personnel files take time to build properly. Agencies that wait for licensure before starting push their first Medicare payment back by months.
- Buying a generic policy manual. Surveyors test whether your practice matches your policies. A template that doesn’t describe how you actually work turns into findings.
- A QAPI plan with no data. It’s one of the most common findings for new agencies. The plan has to be running, not sitting in a binder.
- Gaps in staff files. One missing competency check or one expired license across a handful of files is enough for a deficiency.
Build accreditation-ready from day one
The agencies that launch smoothly treat accreditation as part of how the agency is designed. Their policies match their workflows. Staff files are complete from the first hire. QAPI starts collecting data with the first patient. When the surveyor walks in, there is nothing to scramble for.
One timing note: CMS paused new Medicare enrollment for home health agencies and hospices on May 13, 2026. If you’re planning around that, read why accreditation prep should start before the freeze ends.
How we help
Our accreditation support covers ACHC, CHAP and Joint Commission readiness, from the initial readiness assessment through policies written to the standards, QAPI set-up, survey preparation and post-survey follow-up. We prepare and submit the package for you, at one fixed price agreed up front.
Planning a Medicare-certified home health agency or hospice? Book a free discovery call and we’ll tell you which accreditor fits your state and services, and how long the road to billing really is.
This article is general information, not legal advice. Accreditation standards and CMS requirements change; we confirm the current rules for your state and accreditor as part of every project.
