By Robin Stawasz

Nothing is quite as disruptive to a hospice organization as a licensing survey. When the surveyors show up, all routine is disrupted as staff anxiously wait to see what they will find. Since good preparation can go a long way in avoiding or mitigating any deficiencies, it is vital that to know what CMS and state surveyors will be focusing on.

For the first time since 2019, CMS has issued a 196-page update to the hospice survey process. This update is effective immediately. CMS added requirements for their surveyors to undertake online investigation of the targeted hospice prior to their arrival, including looking at Care Compare quality metrics and researching background information. Hospices must be vigilant on their Care Compare measures which requires proactive steps to control, as well as very purposeful in their marketing. 

In addition, CMS will now be sampling patients from GIP, routine home care, and continuous care. Hospices who do not offer all levels of care will find themselves at risk. Surveyors will be digging deeper into the patient and family experience with a level of scrutiny that hospices have not yet experienced. Hospices who are surveyed by accredited organizations will find that CMS may now check on the validity of such surveys as they have not done in the past. While much of this seems overwhelming, especially as hospices continue to deal with workforce shortages and narrow operating margins, there is some hope. This update provides a level of consistency and standardization that has long been lacking in the survey process. And hopefully this level of scrutiny will find out those bad-acting organizations who are hospices in name only.

If you would like help making sense of this change, Acclivity is here for you – please contact us.

Source Materials: “CMS Overhauls Hospice Survey Process in Newly Published Guidance” by Liza Berger posted by McKnights Home Care on January 31, 2023 ( and “Revisions to Hospice-Appendix M of the State Operations Manual and the Hospice Basic Surveyor Training” released by CMS released on January 27, 2023 (

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