Home Care Agency Compliance Checklist

What is required. Every caregiver must have a complete personnel file containing: proof of required certification (CNA, HHA, or applicable state credential); a current, clear background check from your state's nurse aide or caregiver registry and from a national criminal background check service; a current TB test or chest X-ray (typically required annually); CPR and first aid certification (typically valid for two years); completed orientation documentation; required training hours with dates and competency verifications; a signed job description; an annual performance evaluation (required in most states); and emergency contact information.

What surveyors look for. The surveyor will typically pull a random sample of five to ten personnel files and check each item above. A single expired CPR certification is a deficiency. Three expired CPR certifications in a file sample of five is a pattern — and a pattern elevates the inspection. The most common personnel file deficiency at small agencies is not missing documentation at intake; it is documentation that was current at hire and has since expired without anyone noticing.

What the calendar requires. Every credential in every personnel file needs an expiration date entered in a tracking system with an alert set 45–60 days before expiration. CPR renews every two years. TB tests renew annually. State certifications renew on a state-set schedule. With 15 caregivers, you have roughly 45–60 individual expiration dates to track. A spreadsheet can manage this, but it requires someone to check it at least weekly and act on what it shows. For a complete guide to building this system, see How to Track Caregiver Credentials.

What is required. Every active client must have a complete record containing: an initial comprehensive assessment or intake evaluation; a current care plan that reflects the client's actual condition, care needs, and service schedule; authorization documents for the current service period; supervisory visit records at the required frequency (most states require a supervisory visit every 60 to 90 days, and some require more frequent visits for certain client populations); incident reports for any reportable events; and physician or nurse practitioner orders for any skilled elements of the care plan.

What surveyors look for. The care plan review date is the most scrutinized element. A care plan that has not been reviewed since intake — even if the client's condition hasn't changed significantly — is a deficiency if the review interval has passed. Surveyors also look at whether the care plan reflects what is actually being delivered: a care plan that describes 20 hours per week when EVV records show 14 is a discrepancy that requires explanation. Incident reports are another common finding — events that should have been reported within 24 to 48 hours but were reported late, or not reported at all.

What the calendar requires. Each client record needs a care plan review date and a supervisory visit due date tracked in a system that generates alerts. At 30 clients with 60-day supervisory visit intervals, you have five to six supervisory visits due per month. If no one owns a calendar that shows which are coming up, some will be missed. At six missed supervisory visits in a survey period, the surveyor does not see six individual oversights — they see a systemic failure in the supervisory visit process.

What is required. Every personal care visit must have compliant EVV data — all six required data elements captured, and any exceptions resolved and documented according to state protocols. Surveyors and MCO auditors may request EVV records for a sample of visits and review the exception resolution log to confirm that exceptions are being addressed in a timely and compliant manner.

What surveyors look for. A high exception rate — more than 5 to 10 percent of visits flagged as exceptions in any period — signals a systemic problem with EVV procedures. Exceptions that are resolved days or weeks after they were generated (rather than within 24 to 48 hours) signal that no one is monitoring the exception queue. Both patterns are cited as deficiencies. For context: an exception that sits unresolved for 60 days is not just a compliance finding — it is a billing failure, because the claim for that visit cannot be submitted until the exception is resolved, and the timely filing window may have closed by then.

What the calendar requires. EVV exception review needs to happen daily or, at minimum, before every billing run. The exception queue should never be more than 48 hours old. For a complete guide to EVV compliance management, see What Is EVV?

What is required. Every licensed home care agency must maintain a written policies-and-procedures manual covering, at minimum: personnel policies (hiring criteria, background check procedures, credentialing requirements, disciplinary process), care delivery policies (service scope, infection control, documentation standards, medication management if applicable), emergency procedures, client rights and grievance procedures, incident reporting procedures, and quality assurance processes. The manual must be reviewed and updated at a defined interval — typically annually — and the review must be documented.

What surveyors look for. Surveyors check three things: that the manual exists and is current (last reviewed within the required interval), that the policies reflect how the agency actually operates (not a template that was filed at licensure and never touched since), and that staff are aware of and following the policies. If a surveyor asks a caregiver how they handle a medication question and the answer doesn't match the written policy, that is a deficiency — even if the caregiver's actual practice is perfectly reasonable.

What the calendar requires. Schedule an annual policies-and-procedures review on a fixed date. Block two hours. Update sections that have changed — EVV procedures, credential requirements, state regulatory changes — and document the review with a signature and date. This is not complex work. It is simply work that needs to happen on a schedule, and that most agency owners do not have on their calendar until after the first citation that references an outdated policy.

What is required. In addition to initial orientation, most states require annual in-service training for all caregivers — a minimum number of hours covering topics specified by state regulation, which typically includes infection control, client rights, abuse and neglect prevention, safety procedures, and any service-specific topics. All training must be documented with the date, content, instructor, and caregiver signature. Some states also require competency evaluations at hire and annually thereafter.

What surveyors look for. Training logs are requested for all caregivers in the personnel file sample. A caregiver who is missing annual in-service hours — even by two hours — is a deficiency. A caregiver whose training documentation exists but does not show the required topics is a deficiency. Surveyors also look at whether required competency evaluations were conducted and documented. This is one of the most reliably cited categories at small agencies because the training often happens informally — in a group meeting, during a shift overlap — and the documentation is incomplete or not filed correctly.

What the calendar requires. Annual in-service training for each caregiver should be scheduled as a calendar event, not an intention. Track completion by caregiver and topic, not just by date. A group training session needs individual sign-in sheets retained in each caregiver's file, not just a general log that a surveyor will not find helpful when they pull individual files.

What is required. Your agency must maintain current copies of: the state home care agency license and any required renewals; liability insurance and workers' compensation insurance certificates with current effective dates; any required surety bonds; all active MCO contracts with current effective dates; proof of any required quality assurance activities; and documentation of any complaints received and how they were resolved. Some states also require maintaining a log of all incidents that occurred and how they were reported and addressed.

What surveyors look for. An expired insurance certificate is an immediate and serious deficiency — it means your agency was operating without required coverage. An expired license renewal is a critical finding that can result in a stop-work order until the renewal is completed. These are the highest-severity single-document deficiencies and the easiest to prevent: they have known expiration dates, and the renewals can be tracked on a calendar years in advance.

What the calendar requires. License renewal dates, insurance certificate expiration dates, and MCO contract renewal dates should all be entered in a tracking system with 90-day advance alerts. These are not frequent — an insurance certificate typically renews annually, a state license every two to three years — but the consequences of missing them are severe enough that tracking them deserves the same systematic attention as caregiver credential expiration.