Home Health’s Top 10 Deficiencies of 2025

We share the most-cited CHAP home health deficiencies and turn them into practical fixes you can implement now. From individualized care plans to med reconciliation, aide supervision, infection control, and transition timelines, we outline simple workflows that hold up on survey day.

• why care plan content remains the top citation
• how to individualize documentation beyond point and click
• full medication reconciliation on every primary visit
• written visit schedules and real patient notification
• patient rights forms and proof of delivery
• infection control habits, bag technique, and equipment cleaning
• aide supervision every 14 days and virtual limits
• transfer and discharge timelines with proof of sending
• using CHAP’s new tools, and three-year trends
• building QAPI projects from deficiency data

After you listen to this podcast, click on some of the links to our resources: our top 10 home health survey deficiency list, which includes our three-year comparison, and the medication reconciliation blog.  

Check out our course: Charting the Course: A Guide to Effective Care Planning in Home Health & Hospice

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Transcript

New Year Kickoff And Why Top 10 Matters

SPEAKER_01 0:15

Greetings and happy new year, happy 2026, and welcome to the first CHAPCAST of 2026. I'm Jennifer Kennedy, the lead for quality and compliance at CHAP. And welcome to our CHAPCAS for 2026. And uh it is the topic of top 10 home health deficiencies today. And I'm with my um compadre and co-worker and friend Kim Skian, and we will regale you with the top 10 CHAP survey deficiencies specifically for home health. And I did a lot of work. This is something that I haven't um done a lot of work on in the past, but now we've shaken things up a little bit, and um quality is taking a bigger lead on top 10 deficiencies uh with a handshake with uh Kimsteam and accreditation. And it's you know it's quite an eye-opener when you look at um those top 10. So uh Kim, let's go ahead and and jump in and let's talk about the roadmap that we're gonna use for this conversation.

Aligning CHAP And CMS Standards

SPEAKER_00 1:30

Sure. Thanks and welcome everybody. Happy New Year. I know we're nearing the end of January, but as our first chapcast, I thought I would set the set the stage and say happy new year, and really hoping for a um a positive uh new year, uh a year ahead for all of us, and both providers and accreditation, or um, us as an AO, as well as, of course, um patients and their families. So we really um do appreciate you joining us to receive this information. I just want to point out that first of all, the top 10 deficiencies in any service line, in this case home health, are extremely important because they do highlight what is most commonly cited. It's important to know that these are our CHAP top 10, but they actually closely align with uh CMS top 10, likely other AOs, and certainly state agencies. So even local local from a state agency, you'll see that these are quite common. And as Jennifer will point out when she talks about some of our additional resources, have also been trends or common over time. Uh it's important that agencies look not only at the top 10 for survey readiness and compliance, but all standards and tags. Um, and in our case, uh you know, we have our CHAP standards, these top 10 standards align with G tags or uh conditions of participation or CMS standards. So it is important that compliance with these with these standards is is of utmost importance to avoid not only CHAP required actions, but also potentially deficiencies, condition or standard level deficiencies during the um the survey.

Using Deficiency Data For Benchmarking

Care Plan Content Stays Number One

SPEAKER_01 3:27

That's great, Kim. And I I think it's really important that um folks be aware that this is another data source for benchmarking, right? You need to um take all your data sources when you can get them, um, from when wherever you can get them, to really benchmark your performance against that data, because that's the only way you'll be able to find gaps in your performance and be able to shore them up through your QuAPI program. So uh even though maybe you did a great job, maybe you had a CHAP survey this year and you did a great job on it, and um you didn't necessarily um have uh many of these or any of these um deficiencies cited, it's important to pay attention because it is another data source, and we need to be data-driven in healthcare in order to be meaningful in our performance improvement. So let's take a look, Kim, at some of the deficiency highlights. If you would um run us through some of those.

SPEAKER_00 4:37

Sure. Uh top of the list, and it has been for the past few years, and honestly, I would say for all service lines, or certainly most of the service lines over time, not just with CHAP, but in general, um we call it APC 10, but it's G574, the content of the individualized plan of care. This is a perpetual top deficiency, um, and the it's really a reminder that the care plan must reflect the patient's individual needs and be updated at least every 60 days or more frequently as needed based on changes in the comprehensive assessment and any other changes. The updates relate to another top 10 um finding, which is also G572, also in the top 10, a little lower down. But the bottom line is that you know, you really have to focus on what matters most to the patient. Of yes, you have to have orders and individual interventions and goals and frequencies for all disciplines and all of the uh, you know, basically conditions that are pertinent to the plan of care and especially that you're providing service, but you want to focus also on what matters most to the patient. For those agencies that um that are uh that that choose to become age-friendly health care at home certified, they understand this because there are the four M's, right? Um, what matters most, mentation, medication, and mobility. But for any organization, uh this this should be a key driver for all care planning to ensure that the clinic care treatment and services are individualized to meet the patient's needs. We did record a previous chapcast on focusing on case management, which is the responsibility of primary the primary care clinician in conjunction with the organization's IDG or IDT, um, other serve other disciplines, um, to but to ensure that there is effective case management to make uh leading the care to make sure that all disciplines, all care services and treatments are reflected.

SPEAKER_01 7:00

Let's talk documentation for a sec, because the electronic medical record is a blessing and a bane. Let's let's be honest with this, you know, and we are in a a time, it doesn't matter whether home health or hospice or you know, whatever your provider type is. We are way past just pointing and clicking. We can't as healthcare providers um that want to um defend their documentation during a survey, during um any any kind of an audit with an audit entity, such as your your Mac or your Smirk or whoever it might be a RAC, whoever it may be, um you have to go beyond point and click. And that's the same for your plan of care. So it has to, you you have to actually do free texting in order to make that an individualized plan of care. And an organization who's not requiring that of their clinicians is is not smart in terms of uh that proactive defense they need to make um for surveys and audits. And um we're not probably uh getting that full picture of the patient without free text individualization as well. So I felt like compelled to drop that in there because um a lot of the EMRs, you know, are are just uh, you know, to use the time-worn phrase, cookie-cutter um phrases, and and you can't rely on point and click at this point uh in the healthcare environment.

SPEAKER_00 8:41

I completely agree, both from a survey regulatory standpoint and of course payment, um, as you pointed out, payment and audit standpoint. And it we're talking about the care plan, but it it also this also includes um um visit notes because it is in the visit notes and the summaries that really paint the picture to then be able to build on the change in the comprehensive assessment and subsequent you know care planning changes. Um, I will say that um uh I will give a shout out to um many of the EMRs that we work with. They've come a long way over the years that there is an ability to be able to modify any you know standard text that's there or you know, add in edit to make sure that that the plan of care does reflect the individual patients' needs and goals. Um, but to your point, it really is up to the organization, the agency, to know um to ensure that the staff are going beyond the point and click to paint the picture of the patient. Absolutely.

Medication Review And Full Med Reconciliation

SPEAKER_01 9:50

So I know we have a few more that stand out as well.

SPEAKER_00 9:55

Oh, yes. Um, medication review, we know that. Um, you know, that's uh we you know we look at at the medications. G536 is the comprehensive assessment that includes the med review. We also have uh presented uh on this topic as well. It is a perennial um top issue, um, and it's really related to ensuring that the medication management as part of a key care planning and assessment responsibility is completed ongoing. And the review that the medication it includes a review that all the medications that the patient is currently using in order to identify potential adverse reactions, um effects, drug reactions, interact interactions, and significant side effects, duplicate drug therapy, etc. We at CHAP recommend uh as a best practice, not it's not a regulatory requirement, we do recommend full medication reconciliation during all nursing and or primary clinician visits so that they can that the medication profile is aligned with what we have in the record, physician orders, and also what the patient is taking in the home or facility. Remember, in home health, we serve patients in assisted living facilities, group homes, residential care homes. So it really is important that that all of all of those lists combine and the patient understands, you know, what it is that they are taking. And the question for every visit is not, have you had any changes to your meds? Because inevitably, you know, there will be one missed, and it'll be found when a surveyor is conducting and does a full med rec. So when we say med review, med rec, it is a full-on review, what's in the home, what's on the patient list in the home, what's in the EMR, and because remember, we also have to provide that in writing, and also what we have for physician orders. And it includes prescription, non-prescription meds, and herbal remedies. Anything to add, Jennifer?

Visit Frequency, Schedules, And Patient Notices

SPEAKER_01 12:08

Well, we just happen to have a really nice resource that we created towards the end of 2025, which is a blog on medication reconciliation. So uh we'll include a link with that uh in this podcast so our listeners can easily access that. Absolutely. Yep, yep.

Patient Rights And Medicare Coverage Notices

SPEAKER_00 12:27

Another is um that we do see in um in in the home, really, is the is that there is not evidence of the written visit frequency and scheduling and patient notification. Uh, we know that under 48460E, there are a several requirements that need to be um, it's specifically written information in the home that needs to be left in the home, which also implies updated. Um now, I I just want to point out really here is the fun the whole the whole reason behind it is number one, pay a patient rights issue to ensure that they are informed of the care that's being provided and when what services are are um you know are in um are treating the patient and when they're coming again. Um and also to make sure that the visit frequency matches physician orders and the care plan. But there's not one specific way that this can be provided. It really does depend on the agency, your agency and the patient. So some patients want a calendar on the fridge, you know, or they have the pre-printed list that the agency provides, or um, they may also use a I've seen whiteboards, right, where that's where the patient chooses to have the information. One point I want to make is we are seeing more frequently the use of the portals, the, you know, like the you know, the the port, the health data portals, the ones between the physicians and my chart, I guess is just an example of one. That is actually okay and will suffice to meet the written requirement as long as the patient and representative understand it, understand that's where where this information is, and can access it. Because, you know, on a survey, we if that's the mode of communication, we would still we would ask them to pull it up to validate. And um, they also should be able to be, they also should be verbally informed with each visit and also informed of any scheduling changes.

SPEAKER_01 14:36

Dare I say that's individualizing the care, isn't it? Yes, it is. Back to issue one.

Infection Control In The Home

SPEAKER_00 14:44

Absolutely. You know, another is the patient rights um requirement that the um patients must receive a written notice in advance of care being furnished, if there's a possibility of not providing care of cover providing cover care or in advance of reducing or terminating ongoing care. This information must be provided both orally and in writing in advance of patient care being initiated and whenever there is a change or termination of care. And just remember that for this, specifically related to home health, there is a CMS documentation requirement in addition to the documentation in the record that that you know indicates that the patient has been informed. And those include the home health change of care notice, the notice of Medicare non-coverage or NOMNOC, the detailed explanation of non-coverage, and ABN or advanced beneficiary notice. Those can be found on the CMS website, but I think EMRs and documentation systems also have them. But it is important that that from a again a regulatory and payment perspective, um, that an agency does make sure that they are providing those documents um as appropriate.

SPEAKER_01 16:06

So we looked at some documentation issues. So let's hop to infection control.

Aide Supervision And Virtual Allowances

SPEAKER_00 16:15

Did you hear the sigh? Oh, I'm waiting for that side for the next one we talk about too, Jennifer. Don't worry. Oh, yeah. Yeah, infection control, not compliant. Fill in the blanks, Kim. Well, nine times out of ten, it or most often, infection control findings are related to a home visit. They have to do with high hand hygiene or a facility, you know, for the in this case a home visit. Hand hygiene and bag technique or and equipment management. So sometimes we'll we'll see it with expired supplies, you know, in supply rooms or in trunk boxes, you know, where the, you know, that's a, you know, a can be a cave of who knows what's in it, you know. So they do make sure that they check them. Supervisors should be checking them ongoing. Um, there also are um some infection control um um findings related to, for example, um the agency's policy on TB testing or you know, other health requirements. But specifically, most commonly, the hand hygiene policy and/or CDC guidance and the CDC guidance is not being followed, they're not washing their hands before they enter the bag between treatments. Um, for example, they are you know using their phone as a piece of equipment, sticking it back in their pocket, picking it back out, you know, and not um not washing their hands again. Uh, if you're using the phone, just like a computer, just like a laptop or a tablet, it's a piece of equipment. And then agencies often get hung on, honestly, their own policy when it comes to bag technique and equipment cleaning and management. Because if they, you know, if your um if your bag technique policy says you cannot have um place the bag directly on the floor, you know, without a barrier, or or you need a barrier, um, you know, that's and and someone misses that, um, that is a finding. Also, um, if your equipment management policy says equipment cleaning, equipment will be cleaned um following manufacturers' guidelines. And those manufacturers' cleaning guidelines, you know, for the product they're using, says you have to clean this for two minutes or treat and let dry for two minutes, you know, that they really have to make sure that they are um, you know, that they are that their policies are reasonable following the CDC guidance. And I think the PSM State Operations Manual has some really good guidance, I think, in in the infection prevent in the infection prevention and control section.

SPEAKER_01 19:03

Absolutely. And even though you know we're way past um, you know, a pandemic, we still need to be mindful of infection control.

SPEAKER_00 19:11

Um and and standard precautions. Following your policy. Yeah, yeah, absolutely. Yep. Um let's go to the next one. No, no, no, no. You're I'm hiding my eyes. I know you are, but guess what? I'm tossing to you on this one because I know it's your favorite. We've been talking about it. My gosh, for 20 years, Jennifer. I feel like we've you and I have been like the bane of our existence, this one. So would you like to team up? Right?

SPEAKER_01 19:38

Yes, it's the supervision minimally every 14 days, you know, and we have um deficiencies in this area. And uh it is what it is, it has to be done. Either you're gonna uh uh have your nurses track it, or you're gonna have somebody else track it internally and cue your nurses. And your aides this to me should come off the list soon and stay off the list. Um we've been saying that. It's a matter of of you know it's a matter of counting when it's due and and actually doing it and documenting that the supervision was completed. So yeah, so that day when I open them up and see that this is on the list.

Transfer And Discharge Timelines

SPEAKER_00 20:26

I don't know what we'll do when it's not anymore, Jennifer. I mean, really, well, we'll have a major celebration. Um, I will add, let's remind uh as a reminder for that aid does not need to be present. Um this is supervision of the RN or the primary clinician supervision of the care plan. And um, and the there are specific, you know, um in the standard specific um questions or areas that that the um that the the person conducting the supervision would follow. In fact, most of the EMRs or many of them have those listed right out. And another best practice, again, not required, but a best practice is to conduct this supervision with every visit, every RN, every primary clinician, if it's a PT-only case, for example, um, so that we don't miss it. There also what we're seeing very recently is um is an issue with GA10, which is the documentation that talks about the ability to have one virtual supervisory assessment in a 60-day episode. And it's extremely um, it's very clear that it says a rare occasion it needed, and it only this this this um this virtual supervision only applies to uh the patients that receive skilled services that are receiving skilled services and aid services under a skilled plan of care for non-skilled um uh patients, they're required to have that supervision every 60 days. Um, again, the aid does not need to be present, but you also need to look at your state requirements because state regulations very often are more stringent. So you want to make sure that your you know the agencies need to make sure that you're you're meeting those requirements and that this supervision is separate from the annual or semi-annual for for um non-skilled, but the on-site there is an on-site visit requirement. Um sounds like we need to with the age present, huh? This sounds like we need to do a blog. Man, do we ever? That's for sure. And I, you know, it is hard to keep up with, which is why we say with med rec and supervision, just do it every visit. You know, every visit every visit. Every, you know, because every RN or primary clinician visit because it does get to be, it's tough to track. Absolutely.

New Tools: Domain Analyses And Three-Year Trends

SPEAKER_01 22:55

All right, Kim, let's talk about how this year's really tippy top um deficiencies compare to last year's.

SPEAKER_00 23:05

Yeah, I mean, like as we have already, you know, indicated, um several that we have discussed already have been on in in previous years, um, but eight um but uh G574 remains as number one, and um the written instructions for and site visit schedule does remain um at number two. Again, most of these men, most of these other findings have also lived in the top 10 over the past few years. Um the one that has become more prominent in the last couple of years is the transfer and discharge documentation, specifically related to the timelines, remembering that they must be um they must be provided not only to the they need to be provided to the physician and the um within uh five business days of a discharge and two business days of a transfer. If once we know of the transfer, if the patient is still in a facility, is still is still um you know admitted or transferred. And that evidence of to make sure that it's clear, uh I'm gonna use a fax, I'm old. So, like facts, you know, the fax statement or whatever the tracking is inside the EMR, they have to be able to demonstrate not only that it was completed in that time period, but that it was sent to the the physician in the facility.

Final Advice And Resource Links

SPEAKER_01 24:33

All right. Well, that's a good overview of um uh of comparison. So um we have some new tools to announce to our customer base for home health. And um, I'll just take a couple minutes, Kim, um, to talk about how we uh shook it up a little bit uh to make it a little more helpful uh for our home health customers. Not only are we giving you a top 10 list this year for 2025 deficiencies, and these are standard deficiencies. Uh we're also giving you an analysis of those top 10 broken into domains. So uh you'll be able to look at your top 10, scroll down on that sheet, and see an analysis of why the um what is the rationale and why the standard is important, some key actions to take, and then some performance improvement suggestions for you to take if that's an issue for your organization. And then another tool that I'm really excited about that that we're doing not only for home health, but each of our provider types that we accredited, we're doing a three-year top 10 deficiency comparison chart with analysis. So we're going in the short way back machine to 2023 and giving you um a side-by-side of 23, 24, and 25 top 10 deficiencies, again with an analysis and an overall uh interpretation of the three-year analysis of those top 10. So uh we're we're really trying to um not just tell you here they are um like we have been in in past years. We're trying to um talk to you about here they are, here's why they're important, here are some things you can do, and um, here are some performance improvement suggestions. So I'm really excited about these tools that we're pushing out the door this year.

SPEAKER_00 26:44

And Jennifer, you should be. I've seen the tools or as they're being developed, and they are incredible, incredibly helpful and informative resources for agencies to be able to use. Um, and to your point at the beginning, uh, this also provides yet another data point, right? To be able to, you know, evaluate their own compliance as well as you know, the industry. I also would add that um our friends in learning solutions here at uh CHAP Center for Excellence, um, the the team uh with uh at CFE will be and Learning Solutions will also is also partnering with partnering with us so that we can make sure that um we are aligned in our own um education to customers, but also that we we have you know a consistent under understanding and um uh awareness of the um of these the challenges and these top deficiencies, but incredible work, Jennifer.

SPEAKER_01 27:45

Yeah, it it it is, and I um you know CHAP is always trying to push the needle forward uh in terms of what we're uh giving our customers. So this is just another way to start 2026 off on a high note. All right, my friend, it looks like we're getting to the end of our time together. Any final thoughts?

SPEAKER_00 28:06

No, I I think, you know, again, just going back to the beginning, you know, this is one uh or two tools that organizations can use in their overall uh survey readiness and education. And um, but it's only it's part of the puzzle, you know, really making sure that that as an agency you understand all of the conditions of participation, um, these uh CMS standards, CHAP standards, and conduct your own internal mock surveys, um, at least annually. I think I've been saying that for years, um, to be able to make sure that um that you know you are in compliance, especially with uh the again, the changes, um, not so much the changes in regulation, but you know, the uh how your organization may apply them, um, especially if you've had change in management, leadership, or staff, because that also tends to be a an area or a time point that there becomes issues. So I just um I'm very happy that we have these resources now to offer.

SPEAKER_01 29:10

Me too, Kim. Thanks. And thanks for uh teaming up with me today to talk about this important topic. You're welcome. So um, what we would invite you to do is um after you listen to this podcast, is uh click on some of the links to our resources, which include our uh top 10 um home health survey deficiency list, our three-year comparison, and then we'll uh also include that link to the medication reconciliation blog that we prepared last year. So thanks to all of you for taking time out of your day to plug into our podcast. From Kim, me, and the entire CHAP staff, keep your quality needle soaring forward, stay safe and well, and thanks for all you do.