Department of Health and Human Services 
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
 
H H A
OME  EALTH  GENCIES 
 
 
R T S
ECEIVED  IMELY  URVEYS 
 
C
AND  ORRECTED 
D A R  
EFICIENCIES  S  EQUIRED 
 
 
 
 
 
 
 
 
 
Daniel R. Levinson   
Inspector General  
 
April 2013 
OEI-06-11-00400   
EXECUTIVE SUMMARY:  HOME HEALTH AGENCIES RECEIVED TIMELY SURVEYS AND 
CORRECTED DEFICIENCIES AS REQUIRED  
OEI-06-11-00400 
 
WHY WE DID THIS STUDY 
 
Over the last decade, the use of home health services increased significantly and Medicare payments to home 
health agencies (HHA) more than doubled. To ensure that HHAs comply with Federal requirements, the 
Centers for Medicare & Medicaid Services (CMS) contracts with each State survey agency (State agency) 
and three accreditation organizations to conduct initial certification surveys of HHAs, recertification surveys, 
and complaint investigations.  CMS also monitors the performance of accreditation organizations by 
contracting with State agencies to perform look-behind surveys of HHAs recently surveyed by 
accreditation organizations. CMS compares an accreditation organizations survey of an individual HHA 
with a State agencys subsequent survey of the same  HHA, and then uses that information in aggregate to 
evaluate the accreditation organizations overall survey performance. A 2008 study by the Office of 
Inspector General (OIG) found that many HHAs had the same deficiencies cited during multiple 
recertification surveys and CMS rarely used the only sanction availableterminationto address HHA 
noncompliance.   
 
HOW WE DID THIS STUDY  
 
Using CMS data for Federal fiscal years 2010 and 2011, we identified the extent to which State agencies and 
accreditation organizations conducted timely recertification surveys of HHAs.  We also identified the extent 
to which HHAs received deficiency citations, corrected deficiencies, or had complaints lodged against them.  
Additionally, we determined the extent to which CMS used  
look-behind surveys to assess the performance of accreditation organizations and State agencies.  
 
WHAT WE FOUND 
 
State agencies and accreditation organizations conducted recertification surveys for nearly all HHAs within 
the required 36-month timeframe and cited 12 percent of HHAs with condition-level deficiencies, the most 
serious type of deficiency.  Ninety-three percent of these HHAs corrected their condition-level deficiencies 
within the required 90-day timeframe; the remaining 7 percent corrected the deficiencies late or left 
Medicare.  Fifteen percent of HHAs had complaints lodged against them; surveyors conducted complaint 
investigation surveys for nearly all of these HHAs and cited 7 percent of them with condition-level 
deficiencies.  With few exceptions, HHAs corrected all condition-level deficiencies cited during complaint 
surveys. State agencies exceeded the required number of look-behind surveys for oversight of accreditation 
organizations. CMS rarely conducted look-behind surveys for oversight of State agencies surveys of HHAs; 
such look-behind surveys are not required by Federal regulation.   
 
WHAT WE RECOMMEND 
  
We recommend that CMS analyze survey data to determine whether it should routinely conduct 
look-behind surveys for oversight of State agencies, which conduct most HHA recertification surveys.   
CMS concurred with our recommendation and stated that its central office will work with the CMS regional 
offices to identify State agencies with the greatest need for look-behind surveys. 
 
   
 
TABLE OF CONTENTS 
 
Objectives ....................................................................................................1 

Background..................................................................................................1 

Methodology................................................................................................7 

Findings......................................................................................................10 

Surveyors conducted recertification surveys on time for  

98 percent of HHAs and cited 12 percent of HHAs with 

condition-level (i.e., serious) deficiencies .....................................10 

Among the HHAs with condition-level deficiencies, 93 percent 
corrected all deficiencies within required timeframes  ...................12 

Surveyors conducted complaint surveys for virtually all of the  
15 percent of HHAs that had complaints lodged against them ......12 

State agencies conducted look-behind surveys of 14 percent  

of HHAs surveyed by accreditation organizations, exceeding 

CMSs 5-percent standard ..............................................................14 

CMS rarely conducted look-behind surveys for oversight of  

State agencies surveys of HHAs; such look-behind surveys        

are not required by Federal regulation ...........................................15 

Conclusion and Recommendation .............................................................16 

Agency Comments and Office of Inspector General Response .....17 

Appendixes ................................................................................................18 

A: The Number and Percentage of Home Health Agencies       

with Condition-Level Deficiency Citations on Recertification 

Surveys During Fiscal Years 201011 ...........................................18 

B: Types of Substantiated Complaints Lodged Against Home
  
Health Agencies During Fiscal Years 201011 ..............................21 

C: Agency Comments  ...................................................................22 

Acknowledgments......................................................................................23 

 
   
   
OBJECTIVES 
1. 	  To determine the extent to which State survey agencies (State 
agencies) and accreditation organizations conducted recertification 
surveys of home health agencies (HHA) within required timeframes 
during fiscal years (FY) 201011.1  
2. 	  To determine the extent to which HHAs received deficiency citations 
on recertification surveys and the nature and resulting actions of those 
deficiencies during FYs 201011. 
3. 	  To determine the extent to which HHAs had complaints  lodged  
(i.e., allegations made) against them, the nature of those complaints, 
and the actions resulting from  those complaints during FYs 201011. 
4.	   To determine the extent to which the Centers for Medicare & Medicaid 
Services (CMS) used look-behind surveys to assess the performance 
of surveyors during FYs 201011. 
BACKGROUND 
HHAs provide home health services for Medicare beneficiaries with  
short- or long-term illnesses or injuries who are confined to their homes 
and need skilled nursing care on an intermittent basis, physical therapy,  
speech therapy and/or continuing occupational therapy.2 In recent years, 
the use of Medicare home health services has grown.  From 2002 to 2010, 
Medicare beneficiaries receiving home health services increased by nearly              
35 percent (from 2.6 to 3.4 million beneficiaries), and the number of 
Medicare-certified HHAs increased by 69 percent (from 6,813 to      
11,548 HHAs).3, 4  In 2010, Medicare paid $19.5 billion for home health 
services, compared to $9.6 billion in 2002. 
Survey and Certification of Home Health Agencies 
All HHAs participating in the Medicare program must comply with 
15 Medicare Conditions of Participation (CoP).5   The CoPs fall into 
two areas: administration and furnishing of services.  Twelve of the 
 
1 All fiscal year references in this report are based on the Federal fiscal year (October  1 
through September 30). 
 
2  Social Security  Act,   1812(a)(3), 1814(a)(2)(C), 1832(a)(2)(A), 1835(a)(2)(A), and 

1861(m). 

3 CMS, Data Compendium, 2003, 2011.  Accessed at https://www.cms.gov  on May 23, 

2012.  From 2002 to  2010, the number of Medicare beneficiary visits conducted  by 
 
HHAs increased by 60  percent (from 78.1 million visits to  124.7 million visits). 
 
4 CMS, Financial Report,  2011, p.  138.   

5 Social Security Act   1861(o)(6) and  1891(a); 42 CFR pt. 484 (subparts B and C). 

Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   1 
   
   
fifteen CoPs are subdivided into standards, which address specific 
aspects of the CoPs.6     
To ensure compliance with the 15 CoPs, CMS enters into agreements with 
State agencies and accreditation organizations to conduct initial 
certification surveys of HHAs, recertification surveys, and complaint 
investigations.7  In this report, we use the term surveyors to refer to both 
State agencies and accreditation organizations.  
Recertification Surveys. Federal law requires that HHAs receive a 
recertification survey at least every 36 months to verify compliance with 
the CoPs.8  Recertification surveys review the quality of care and services  
furnished by the agency as measured by indicators of medical, nursing, 
and rehabilitative care, and include patient home visits and interviews 
with patients and HHA staff.9  Recertification surveys also include a 
review of previous survey data (if available), complaint data, and clinical  
records.10   
Deficiency Citations. If a surveyor determines that an HHA is out of 
compliance with a standard during a recertification survey, the surveyor 
can cite the HHA with a standard-level deficiency.  If the surveyor 
determines that the HHA is out of compliance with a CoP, the surveyor 
can cite the HHA with a condition-level deficiency, the more serious 
type of deficiency.11    
Correcting Deficiencies. If an HHA has one or more condition-level 
deficiencies, it is considered out of compliance with the CoPs.  For such 
noncompliance, the surveyor must provide the HHA with a Statement of 
 
6 The three CoPs that are not defined further by standards are:  release of patient 
identifiable Outcome and Assessment Information Set (OASIS) information  (42 CFR  
 484.11); qualifying to  furnish outpatient physical  therapy or  speech pathology  services 
(42 CFR  484.34); and medical social services (42 CFR   484.38).   
7 Social Security Act,  1891(c)(2)(A) and  1865(a); 42 CFR   488.10(d).  The three 
accreditation organizations approved to conduct surveys are the Accreditation 
Commission for Health Care, the Community Health  Accreditation Program, and the 
Joint Commission.  
8 Social Security Act,  1891(c)(2)(A); CMS, pt. I, section II.E, Recertification Surveys, 
of the Advance Copy of  App.  B to CMS,  State Operations  Manual, Pub. No. 100-07  
(SOM, Advance App. B), attached to CMS Memorandum to State Survey Agency 
Directors, S&C 11-11-HHA, February 11, 2011 (effective May 1, 2011).  For HHA  
recertification surveys, CMS includes 90 percent of the succeeding month to permit 
completion of  any survey in  progress.  See CMS, Division  of Survey and Certification,  
Quality Assurance for the Medicare & Medicaid Programs, FY 2011 Mission  & Priority 
Document, September 3, 2010 (revised  October 15, 2010). 
9 Social Security Act,   1891(c)(2)(C)(i)(II); CMS,  SOM, Advance  App. B, pt.  I,  
section II.B, Standard Survey. 
 
10 CMS, SOM, Advance  App. B, pt. I, section II.E, Recertification Surveys, and pt. I,
  
section III, Task 1, Pre-Survey  Preparation.  

11 CMS, SOM, Advance App. B, pt. I, section III, Task 4, Information Analysis. 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   2 
   
   
Deficiencies and Plan of Correction form that includes evidence to support 
the deficiency citation(s) and a section that HHAs can use to document a 
plan of correction. The HHA must respond with a plan of correction 
within 10 calendar days of receiving this form.12  If an HHA with   
standard-level deficiencies submits an acceptable plan of correction for 
achieving compliance within a reasonable period of time, which is 
generally no longer than 60 days after notification of the deficiencies, the 
surveyor will certify the HHA as in compliance with the CoPs.13    
For an HHA with one or more condition-level deficiencies, a surveyor 
cannot certify compliance based solely on a plan of correction.  In these 
cases, CMS must place the HHA on a 90-day termination track (the only 
enforcement remedy currently available to CMS).14, 15  To  continue 
participating in Medicare, the HHA must submit a credible allegation of  
compliance, and achieve compliance or acceptable progress within the 
90-day timeframe.16  If a surveyor documents immediate jeopardy to 
patient health and safety, the State agency must place the HHA on a  
23-day termination track, using the same procedures as the 90-day 
termination track.17  
Complaint Investigations. Medicare beneficiaries, families of  
beneficiaries, HHA staff, physicians, and others can lodge complaints 
against HHAs to a variety of entities, including State agencies, 
accreditation organizations, and CMS.  CMS and State agencies track 
complaints lodged, categorize them into different severity levels, and 
determine actions to take (e.g., referral to another agency, offsite 
 
12 CMS, SOM, Pub. No. 100-07, ch. 2,  2728, 2728A, and 2728B.   

13 Ibid.   An acceptable plan of correction must include the following elements:  plan of 

correcting the  specific deficiency and addressing the processes that led to the deficiency 

cited; procedure for implementing the acceptable plan  of correction for the specific 

deficiency cited; monitoring  procedure to ensure that the plan of correction is effective 

and that specific deficiency cited remains corrected and/or in  compliance with the 

regulatory requirements; and title of the person responsible for implementing the 

acceptable plan of correction. 

14 CMS, SOM, ch. 3,  3012.   

15 On  November 8, 2012, CMS issued a final rule to implement intermediate (or 

alternative) sanctions for noncompliant  HHAs.  For more information  on this rule, see the 
Other Studies section on  page 6.  
16 CMS, SOM, ch. 3,  3016A.  Credible allegation of compliance is defined as a 
statement or  documentation:  that is realistic in terms of the possibility of  corrective 
action being accomplished between the exit conference and the date  of allegation; and 
that indicates resolution  of the problems.  
17 CMS, SOM, ch. 3,  3010B.  
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   3 
   
   
investigation, onsite investigation) on the basis of those severity levels.18   
CMS and State agencies categorize lodged complaints into one of eight 
severity levels, and CMS requires surveyors to conduct complaint 
investigation surveys (hereafter referred to as complaint surveys) for the 
three most severe of these: 
 	  Immediate jeopardy:  Providers noncompliance with the CoPs has 
caused or is likely to cause serious injury, harm, impairment, or 
death.19    
 	  Non-immediate jeopardy high:  Providers noncompliance with the 
CoPs may have caused harm that negatively affects the 
individuals mental, physical, and/or psychosocial status and is of 
such consequence to the persons well-being that a rapid response 
by the State agency is indicated.20    
 	  Non-immediate jeopardy medium:  Providers noncompliance with 
the CoPs caused or may cause harm that is of limited consequence 
and does not significantly impair the individuals mental, physical, 
and/or psychosocial status or function.21    
Surveyors conducting complaint surveys focus on the specific regulatory 
requirements related to the complaint lodged.  If surveyors identify 
significant problems, the surveyors can expand the survey to review the 
HHAs compliance with other CoPs.22 If surveyors find evidence 
supporting the complaint, the surveyors substantiate the complaint.23   
During a complaint survey, surveyors not only determine whether the 
complaint is substantiated, but also cite any deficiencies found, which may 
or may not directly relate to the complaint.  If surveyors find 
condition-level deficiencies, they can place the HHA on a termination 
track. To continue participating in Medicare, the HHA must submit an 
 
18 CMS, SOM, ch. 5,   5075.15075.8.  CMS and State agencies categorize lodged 
 
complaints into  one of the following eight  severity levels:  immediate jeopardy, 

non-immediate jeopardy high, non-immediate jeopardy medium, non-immediate jeopardy
  
low, administrative review/offsite investigation, immediate referral, other referral, and no
  
action necessary. 

19 CMS, SOM, ch. 5,  5075.1, p.  14. 

20 CMS, SOM, ch. 5,  5075.2, p.  15.  Although the SOM  states that only nursing home 

complaintsas opposed to complaints regarding other facilitiescan  be  categorized at 

the level non-immediate jeopardy  high, a  CMS official explained that some complaints
  
lodged against HHAs are also  categorized at this level and  require complaint surveys 

within 2 or 10 days. 
 
21 CMS, SOM, ch. 5,  5075.3, p.  16. 

22 CMS, SOM, ch. 5,  5200.1, p.  33. 

23 CMS, SOM, ch. 9, Exhibit 23. 
 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   4 
   
   
acceptable plan of correction, as it does when deficiencies are cited during 
a recertification survey.24  
For the other five levels of complaints lodged, the surveyor can wait until 
the next survey to review the issue related to the complaint.25   
Additionally, surveyors can refer the complaint to another agency or entity  
(e.g., law enforcement or licensure agency) for investigation or for 
informational purposes.26  
Look-Behind Surveys of Accreditation Organizations and 
State Agencies 
Federal law requires that CMS annually report to Congress about the 
performance of accreditation organizations.27  To assess these 
organizations performance, CMS enters into agreements with State 
agencies for the agencies to annually conduct look-behind surveys of a 
representative sample of at least 5 percent of HHAs surveyed by 
accreditation organizations.28   These surveys (which CMS refers to as 
validation surveys) enable CMS to compare an accreditation 
organizations results for an individual HHA with those from a State 
agencys subsequent survey of the same HHA.   
The look-behind survey, which a State agency must conduct no later than 
60 days following an accreditation organizations survey of the same  
HHA, reviews the HHAs compliance with the CoPs.  During a 
look-behind survey, the State agency can cite the HHA with deficiencies in 
the same way as during a certification or recertification survey.  Once the 
State agency completes the survey, it provides CMS with the survey 
results. For each HHA that receives a look-behind survey, CMS compares 
the condition-level deficiencies identified by the State agency to those 
identified by the accreditation organization.29   CMS uses this information 
in aggregate to calculate a disparity rate, which is the percentage of all 
look-behind surveys in which the accreditation organization missed a 
condition-level deficiency identified by a State agency.30     
 
24 CMS, SOM, ch. 5,  5200.1, p.  33. 

25 CMS, SOM, ch. 5,   5075.4, 5075.5, and 5075.8. 

26 CMS, SOM, ch. 5,   5075.65075.7. 

27 Social Security Act,   1875(b). 

28 CMS, Division  of Survey and Certification,  Quality Assurance for the Medicare &  

Medicaid Programs, FY 2011 Mission  & Priority Document, September 3, 2010  (revised 
October 15, 2010).   
29 CMS, Financial Report, 2010, p. 152. 
30 Ibid., p.  154.  The disparity rate is calculated  by taking the number of look-behind  
surveys in  which a State agency found at least one condition-level deficiency that a given  
accreditation organization had missed for the same HHA, and dividing it by the total 
number of look-behind surveys for that accreditation organization.  
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   5 
   
   
Federal law does not require CMS to conduct look-behind surveys to 
assess State agencies performance in surveying HHAs, but CMS may 
conduct such surveys if it wishes. In these cases, CMS itself conducts the  
look-behind survey of an HHA, rather than contracting with another entity 
to do it. CMS then compares its results for an individual HHA with the 
State agencys results for the same HHA.  Although look-behind surveys 
to evaluate State agencies performance (surveys that CMS refers to as 
Federal monitoring surveys) are not required vis-a-vis State agencies  
surveys of HHAs, they are required for State agencies surveys of nursing  
homes, which serve beneficiary populations similar to those of HHAs, and 
CMS routinely conducts such surveys.31  
Other Studies 
A 2008 report by the Office of Inspector General (OIG) found that many 
HHAs had the same deficiencies cited during multiple recertification 
surveys.32  Further, the study found that CMS rarely used the only sanction 
availableterminationto address HHAs with repeated deficiencies.  In 
the report, OIG recommended that CMS implement intermediate sanctions 
for HHAs as required by the Omnibus Budget Reconciliation Act of 
1987.33  In March 2012, OIG reiterated this recommendation in an early 
alert memorandum to CMS that outlined CMSs limited action toward 
promulgating regulations for the HHA intermediate sanctions.34 In 
November 2012, CMS issued a final rule to implement intermediate (or 
alternative) sanctions for noncompliant HHAs.  The first set of sanctions, 
which will become effective on July 1, 2013, includes temporary 
management, directed plans of correction, and directed in-service training.  
Two additional sanctionscivil money penalties and suspension of  
Medicare payments for new patient admissionswill become effective on 
July 1, 2014.35    
 
31 Social Security Act,  1819(g)(3)(B)(Medicare) and  1919(g)(3)(B)(Medicaid); CMS, 
SOM, ch. 4,   4157D.  Federal law requires CMS to conduct look-behind  surveys of at 
least 5 percent of the number of nursing homes surveyed by each State agency each year, 
but in  no case is CMS to survey fewer than  five nursing homes in each State per year.   
32 Department of Health and Human Services (DHHS), OIG,  Deficiency History and 
Recertification of Medicare Home Health Agencies, OEI-09-06-00040, August  2008. 
33  Omnibus  Budget Reconciliation Act of  1987, P.L. 100-203,  4023 (adding  Social 
Security Act,   1891(e) and (f)). 
34 DHHS,  OIG,  Early Alert Memorandum Report: Intermediate Sanctions for 
Noncompliant Home Health Agencies, OEI-06-11-00401, March 2012. 
35  77  Fed.  Reg. 67068 (November 8, 2012).  
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METHODOLOGY 
Scope 
This evaluation examines all Medicare-certified HHAs that received a 
recertification survey, had a complaint lodged against them, and/or 
received a look-behind survey during FYs 201011.  Consequently, this 
evaluation does not include HHAs that did not receive a recertification 
survey during FYs 201011. 
Data Collection and Analysis 
To analyze all HHA recertification surveys and complaints during          
FYs 201011, we obtained data from three CMS databases:  the 
Automated Survey Processing Environments (ASPEN), the Certification  
and Survey Provider Enhanced Reporting (CASPER), and the Accrediting 
Organization System for Storing User Recorded Experiences (ASSURE).  
ASPEN and CASPER store data from recertification surveys conducted by  
State agencies and include all HHA enrollment, termination, and 
complaint data.  ASSURE stores data from HHA recertification surveys 
conducted by accreditation organizations.  To analyze look-behind 
surveys, we obtained copies of Statement of Deficiencies forms from  
CMS. 
Recertification Surveys. We identified all HHAs that received a 
recertification survey during FYs 201011, using data from  ASPEN and 
CASPER for surveys conducted by State agencies and ASSURE for 
surveys conducted by accreditation organizations.36  To identify and 
calculate the percentage of HHAs that received a recertification survey 
within the required timeframe, we counted the number of working days 
since the prior recertification survey date.37 For each recertification 
survey, we identified all deficiency citations and calculated the percentage 
of HHAs with citations.  We focused additional analysis on citations for 
condition-level deficiencies, the more serious of the two kinds of 
deficiencies.  We identified whether HHAs corrected their condition-level 
deficiencies, returned to compliance within the required 90-day timeframe, 
or were terminated from Medicare.  For each scenario, we calculated the 
associated percentage of HHAs. 
 
36 This analysis included only recertification surveys, not other types of surveys such as 
initial certification  surveys. 

37 We used 36.9 months as our criteria for calculating surveys conducted within the 

required timeframe because CMS includes 90 percent of the succeeding month to permit 

completion of  any survey in  progress.  See CMS, Division  of Survey and Certification,  

Quality Assurance for the Medicare & Medicaid  Programs, FY 2011 Mission & Priority 
Document, September 3, 2010 (revised  November 15, 2010). 
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Complaints and Complaint Surveys. We used ASPEN to identify all 
HHAs that had a complaint lodged against them alleging noncompliance 
during FYs 201011.38   We calculated the percentage of HHAs with any 
complaints lodged and identified the severity of those complaints.  We  
also calculated the percentage of HHAs with substantiated complaints and 
the percentage of HHAs that received a complaint survey.  Although 
ASPEN indicated that HHAs received a complaint survey, ASPEN did not 
contain records of the survey results for all HHAs.  More specifically, it 
was missing one or more survey records for 261 HHAs that received a 
complaint survey.39 As a result, our analysis of complaint surveys 
included only HHAs for which ASPEN had survey records.40 For each 
complaint survey, we identified all deficiency citations and calculated the  
percentage of HHAs with such citations.  We focused additional analysis 
on citations for condition-level deficiencies and identified whether HHAs 
corrected these deficiencies, returned to compliance within the required 
90-day timeframe, or were terminated from Medicare. 
Look-Behind Surveys. We identified all HHAs that received a look-behind 
survey during FYs 201011 using Statement of Deficiencies forms 
obtained from CMS.  For State agencies, we identified whether surveyors 
each year collectively conducted look-behind surveys of 5 percent of 
HHAs surveyed by accreditation organizations, as required by CMS.  For 
each look-behind survey, we identified condition-level deficiencies cited 
by State agencies but missed by accreditation organizations.  Using this 
information, we calculated a disparity rate across the three accreditation 
organizations.  Lastly, we identified the extent to which CMS voluntarily 
conducted look-behind surveys of State agency-surveyed HHAs to assess 
State agencies performance.  
Limitations 
This study has two limitations.  First, we did not compare deficiency 
citation rates between HHAs surveyed by State agencies and those 
surveyed by accreditation organizations because the surveying entities 
conduct recertification surveys differentlythough all State agencies use 
similar survey instruments and methodology, each accreditation 
organization uses its own process.  Moreover, although accreditation 
organizations must match their deficiency citations to those used by State 
 
38 In  our analysis, we did not include any complaints  unrelated to the Federal  
requirements, such as complaints related solely to State matters, which  were outside the 
scope of the study.  
39 A CMS official indicated that a failure of the complaint survey records to upload into  
ASPEN may likely be the cause of the missing records. 
 
40 This analysis includes only complaint surveys, not other types of surveys such as initial 

certification surveys. 

Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   8 
   
   
agencies, a deficiency cited by an accreditation organization may not 
correspond directly to a deficiency cited by a State agency.  Second, we 
could not include all HHAs that received a complaint survey in our 
analysis because ASPEN was missing one or more complaint survey 
records for 261 HHAs. 
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors General 
on Integrity and Efficiency. 
   
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   9 
   
   
FINDINGS 
Surveyors conducted recertification surveys on time 
for 98 percent of HHAs and cited 12 percent of HHAs 
with condition-level (i.e., serious) deficiencies  
Surveyors conducted recertification surveys of 6,316 HHAs during  
FYs 201011.  Eighty-two percent of these HHAs (5,210) were surveyed 
by State agencies, whereas 18 percent (1,106) were surveyed by 
accreditation organizations.  Ninety-eight percent of these 6,316 HHAs 
(6,190) received a recertification survey within the required 36-month 
timeframe.  For the remaining 2 percent of HHAs (126), surveyors were 
late in conducting the survey by a median of 3.3 months.  Of the 
126 HHAs that were surveyed late, 32 HHAs were not surveyed until 
more than a year after the required 36-month timeframe.   
Collectively, surveyors cited 12 percent of HHAs with at least 
one condition-level deficiency, but citation varied widely by 
State agency and by accreditation organization  
Among the 6,316 HHAs that received a recertification survey, surveyors 
cited deficienciesincluding both standard-level and condition-level 
deficienciesfor 74 percent (4,694).  For the remaining 26 percent of 
HHAs (1,622), surveyors cited no deficiencies.  Among the 74 percent of 
HHAs with deficiencies, surveyors cited 62 percent (3,942 of 6,316) with 
standard-level deficiencies only, and cited an additional 12 percent (752 of 
6,316) with at least one condition-level deficiency, the more serious type 
of deficiency (see Figure 1). 
Figure 1: HHAs With Deficiency Citations on Recertification Surveys  
 
 
 
 
 
 
 
Source:  OIG analysis of 6,316 HHAs  recertification surveys in FYs 201011. 
 
   
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)  10  
   
   
Among the HHAs with condition-level deficiencies, surveyors found 
noncompliance across all 15 CoPs and cited a total of  
1,736 condition-level deficiencies.  Fifty-four percent of these HHAs  
(409 of 752) received two or more condition-level deficiency citations.41   
The HHA with the most condition-level deficiencies was cited for 13 of 
the 15 CoPs. 
The most frequently cited condition-level deficiency among these HHAs, 
cited for 35 percent of HHAs (265 of 752), involved noncompliance with 
acceptance of patients, plan of care, and medical supervision.  (Table 1 
lists the number and percentage of HHAs with condition-level deficiencies 
in each of the 15 CoPs.)   
Table 1: HHAs Cited With Condition-Level Deficiencies, by Condition of 
Participation 
HHAs Cited With  
Condition-Level  
Condition of Participation*   Percentage 
Deficiency  
(n=752)  
Acceptance of patients, plan of care and medical 
265  35%  
supervision  
Organization, services and administration  241  32%  
Skilled nursing services  200  27%  
Clinical records  183  24%  
Evaluation of the agencys program  157  21%  
Comprehensive assessment of patients  145  19%  
Reporting OASIS  information   145  19%  
Group of professional personnel   130  17%  
Home health aide services  129  17%  
Patient rights  42  6%  
Therapy services  42  6%  
Compliance with Federal, State, and local laws   30  4%  
Medical social services  21  3%  
Release of patient personally  identifiable information  5  <1%  
Outpatient physical therapy or speech pathology services  1  <1%  
Note: Some HHAs had more than one recertification survey and could have received a condition-level deficiency 
 
citation  for the same CoP more  than once; however, we counted each HHA only once for each CoP. 

*See 42 CFR pt. 484 (subparts B and  C). 

Source:  OIG analysis of 752 HHAs cited with condition-level deficiencies on recertification surveys in  

FYs 201011.  

 
Surveyors varied in the percentages of HHAs they cited with  
condition-level deficiencies during recertification surveys.  State agencies 
gave condition-level deficiency citations to between 0 and 50 percent of 
the HHAs they surveyed. Despite conducting recertification surveys for 
 
41 Surveyors cited 343 HHAs with 1 condition-level  deficiency, 164 HHAs with  2, 
107 HHAs with 3,  and 138 HHAs with 4 or more condition-level deficiencies. 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   11  
   
   
multiple HHAs, nine State agencies did not cite any condition-level 
deficiencies, whereas eight State agencies cited condition-level 
deficiencies for 20 percent or more of the HHAs receiving recertification 
surveys. (See Appendix A-1 for the number and percentage of HHAs that 
were cited for condition-level deficiencies, by State.)  Accreditation 
organizations gave condition-level deficiency citations to between 8 and 
33 percent of the HHAs they surveyed.  (See Appendix A-2 for the number 
and percentage of HHAs with condition-level deficiencies, by 
accreditation organization.)   
Among the HHAs with condition-level deficiencies,  
93 percent corrected all deficiencies within required 
timeframes 
Surveyors placed nearly all HHAs with condition-level deficiencies  
(741 of 752) on a 90-day termination track.  Ninety-three percent of HHAs  
(692 of 741) with condition-level deficiencies corrected all deficiencies 
and returned to compliance within the required 90-day timeframe.  These 
HHAs returned to compliance an average of 38 days following the 
recertification survey.   
The remaining 7 percent of HHAs (49 of 741) did not return to 
compliance within the 90-day timeframe.  Among these 49 HHAs,  
33 corrected their deficiencies shortly after the 90-day timeframe, 
returning to compliance an average of 130 days following the 
recertification survey.  However,  one HHA did not return to compliance 
until more than a year after the recertification survey.  A CMS official 
explained that HHAs likely exceeded the timeframe because surveyors did 
not conduct timely followup visits or provide the HHAs with a statement 
of deficiencies, typically resulting in an extension of the termination date.  
Another 16 of the 49 HHAs never corrected their condition-level 
deficiencies; CMS terminated the Medicare participation for 8 of these 
HHAs, and 3 HHAs voluntarily discontinued their participation.  The 
remaining five HHAs continued participation in Medicare, yet CMS could 
not determine whether the HHAs corrected their deficiencies.   
Surveyors conducted complaint surveys for virtually 
all of the 15 percent of HHAs that had complaints 
lodged against them 
CMS received 5,888 complaints concerning 1,784 HHAs (15 percent of all 
HHAs) in FYs 201011.  CMS classified the complaints42 lodged against 
 
42 In this report, the term complaint means (unless specified  otherwise) a complaint that 
has been lodgedi.e., an allegation. 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   12  
   
   
7 percent of HHAs (126 of 1,784) as immediate jeopardy, the most severe 
level of complaint.  The most common severity level of complaints lodged 
was non-immediate jeopardy medium, accounting for 78 percent of all 
HHAs (1,387) with complaints lodged against them.  (Table 2 lists the 
number and percentage of HHAs with complaints lodged against them, 
categorized by severity level.) 
Table 2: Complaints Lodged Against HHAs, by Severity  Level  
HHAs With Complaints 
Severity Level of Complaints Lodged  
(Most Severe to Least Severe)   Lodged Against  Them  Percentage 
(n=842) 
Immediate jeopardy  126  7%  
Non-immediate jeopardy high   143  8%  
Non-immediate jeopardy medium   1,387   78%  
Non-immediate jeopardy low  239  13%  
Non-immediate jeopardy administrative 
108  6%  
review/offsite investigation 
Referralimmediately  3  <1%  
Referralother  8  <1%  
No action necessary   1  <1%  
Note: Some HHAs had more than one complaint lodged against them; however, we  counted each HHA only 
 
once for each complaint severity level. 

Source:  OIG analysis of 1,784 HHAs with complaints lodged against them in FYs 201011. 

Surveyors conducted complaint surveys for 1,781 of the 1,784 HHAs that 
had one or more complaints lodged against them.  For the remaining  
three HHAs, surveyors neither conducted nor required a complaint survey.   
Surveyors found supporting evidence and substantiated at least  
one complaint for 47 percent of HHAs (842 of 1,784) with complaints 
lodged against them.  Two or more complaints were substantiated for 
nearly 70 percent of these HHAs (586 of 842).43  For one HHA alone, 
surveyors substantiated 25 complaints.  The most common type of 
complaint, substantiated for 523 HHAs, related to quality of care and 
treatment of patients.  (Table 3 lists the most common types of complaints 
lodged and substantiated against HHAs and Appendix B provides a 
comprehensive list of lodged and substantiated complaints.)    
Of the 1,615 HHAs with complaint survey records stored in ASPEN, 
7 percent (113 of 1,615) were cited with at least one condition-level 
deficiency.44  Surveyors cited an additional 39 percent of HHAs   
 
43  Two hundred fifty-six HHAs  had one  substantiated complaint,  196 HHAs had  2,  
164 HHAs  had  3,  87 HHAs  had 4, and 139 HHAs had 5 or  more substantiated 
complaints. 
44 As previously stated, we could not include in this analysis the 261 HHAs that received 
a complaint survey but lacked records of the survey results in ASPEN. 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   13  
   
   
(636) with standard-level deficiencies only.  For the remaining 54 percent 
of HHAs (866), surveyors cited no deficiencies.  
Table 3: HHAs With Substantiated Complaints, by Complaint Type  
HHAs With Complaints  HHAs With  
Description of Complaint   Lodged Against  Them  Substantiated 
(n=1,784)   Complaints (n=842)  
Quality of care/treatment   1,089   523 
Administration/personnel  665  312 
Patient rights  622  250 
Nursing services  370  156 
Admission, transfer, and discharge rights  286  124 
Falsification of records/reports   207  88 
Fraud/false billing  175  72 
Patient neglect  167  77 
Note: Some HHAs had more than one complaint lodged against them and/or more than one substantiated 
 
complaint; however, we counted each  HHA only once for  each complaint description. 
 
Source:  OIG analysis of 1,784 HHAs with complaints lodged against them in FYs 201011. 

 
With few exceptions, HHAs corrected all condition-level 
deficiencies cited during complaint surveys 
Surveyors placed all HHAs that were cited for a condition-level deficiency 
during a complaint survey on a 90-day termination track.   
Eighty-two percent of HHAs (93 of 113) that were cited for  
condition-level deficiencies corrected all deficiencies and returned to 
compliance within required timeframeson average, 32 days following 
the complaint survey.  Among the 18 percent of HHAs (20 of 113) that did 
not return to compliance as required, CMS terminated the Medicare 
participation of 9 HHAs, and another 4 HHAs voluntarily discontinued 
their participation. The remaining seven HHAs corrected their 
condition-level deficiencies after the required 90-day timeframe, returning 
to compliance, on average, 120 days following the complaint survey.   
State agencies conducted look-behind surveys of      
14 percent of HHAs surveyed by accreditation 
organizations, exceeding CMSs 5-percent standard 
Accreditation organizations conducted recertification surveys of 
18 percent of all HHAs (1,106 of 6,316) during FYs 201011.  To monitor 
accreditation organizations performance during this time, State agencies 
conducted look-behind surveys of 14 percent (153) of the 1,106 HHAs 
surveyed by the three accreditation organizations.  This exceeded CMSs 
5-percent standard for look-behind surveys of HHAs surveyed by 
accreditation organizations.  For 24 of the 153 HHAs that received a 
look-behind survey, State agencies identified condition-level deficiencies 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   14  
   
   
that accreditation organizations missed, resulting in an overall 16-percent 
disparity rate. 
CMS rarely conducted look-behind surveys for 
oversight of State agencies surveys of HHAs; such 
look-behind surveys are not required by Federal 
regulation 
Although State agencies conduct most recertification surveys (82 percent 
of all HHAs during FYs 201011), Federal regulations do not require 
CMS to perform look-behind surveys to assess State agencies survey 
performance.  Further, during FYs 201011, CMS rarely conducted such 
surveys. Specifically, among the 5,210 HHAs that received recertification 
surveys from State agencies, 5 HHAsabout one-tenth of 1 percent 
received a look-behind survey from CMS, with all 5 surveys occurring in 
FY 2010. The small number of look-behind surveys prevents any 
conclusion as to the usefulness of conducting such surveys.  It also 
prevents CMS from calculating disparity rates for State agencies surveys 
of HHAs and thus from using these rates to evaluate State agencies in the 
manner it evaluates accreditation organizations.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   15  
   
   
CONCLUSION AND RECOMMENDATION 
Over the last decade, the use of home health services increased 
significantly and Medicare payments for such services and the number of 
HHAs both more than doubled.  CMS is responsible for ensuring that 
HHAs comply with Federal requirements and provide quality care, and 
CMS relies on State agencies and accreditation organizations to verify 
HHAs compliance through onsite surveys and complaint investigations.  
Overall, we found that surveyors conducted recertification surveys and 
investigated complaints as required and that HHAs cited with  
condition-level deficiencies took corrective action during FYs 201011.  
To assess accreditation organizations survey performance, CMS 
contracted with State agencies to conduct look-behind surveys of HHAs 
surveyed by accreditation organizations.  However, CMS is not required to 
conduct, and rarely conducted, similar look-behind surveys to assess State 
agency survey performance.  Given that State agencies conducted the vast 
majority of HHAs recertification surveys (82 percent in FYs 201011) 
and demonstrated wide variation in citing condition-level deficiencies, the 
lack of look-behind surveys for oversight of State agencies could present a 
vulnerability to program effectiveness and quality of care for Medicare 
beneficiaries. By way of comparison, CMS is required to conduct, and 
routinely conducts, look-behind surveys of State agency-surveyed nursing 
homes, which serve beneficiary populations similar to those of HHAs. 
We recommend that CMS: 
Analyze Survey Data to Determine Whether It Should Routinely  
Conduct Look-Behind Surveys for Oversight of State Agencies  
CMS should analyze existing survey data to determine whether to assess 
State agency survey performance and implement routine look-behind 
surveys of HHAs surveyed by State agencies.  Conducting look-behind 
surveys for State agencies in the same manner as those that CMS is 
required to conduct for accreditation organizations would provide CMS 
with disparity rates for State agencies.  Considering that many State 
agencies cited few or no condition-level deficiencies for HHAs during 
recertification surveys, look-behind surveys would also provide CMS with 
insight regarding variation among States in issuing condition-level 
deficiency citations.  
   
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   16  
   
   
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL  
RESPONSE 
CMS concurred with our recommendation to analyze survey data to 
determine whether it should routinely conduct look-behind surveys for 
oversight of State agencies.  CMS stated that its central office will work 
with the CMS regional offices to identify State agencies with the greatest  
need for look-behind surveys.  CMS also stated that it will evaluate other 
oversight options to monitor State agency performance.  For the full text 
of CMSs comments, see Appendix C. 
   
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   17  
   
   
APPENDIX A 
The Number and Percentage of Home Health Agencies Cited 
With Condition-Level Deficiencies on Recertification Surveys 
During Fiscal Years 201011 
Table A-1: Home Health Agencies Cited With Condition-Level Deficiencies  
on Recertification Surveys Conducted by State Survey Agencies During  
Fiscal Years 201011  
Home Health  Agencies   Percentage of HHAs  
HHAs Cited With  
(HHA) Receiving a  Cited With 
State   Condition-Level  
Recertification Survey   Condition-Level  
Deficiencies (n=542) 
(n=5,210)   Deficiencies  
U.S. Virgin Islands  2  1  50%  
Michigan  64  31  48%  
Idaho  27  9  33%  
Montana  24  8  33%  
Colorado  86  25  29%  
Nevada  35  8  23%  
California  375  74  20%  
Maine  5  1  20%  
Kansas  98  15  15%  
Puerto Rico   20  3  15%  
Arizona  51  7  14%  
Ohio  308  42  14%  
Vermont  7  1  14%  
Indiana  135  17  13%  
New Mexico  39  5  13%  
Alabama  65  8  12%  
Florida  351  37  11%  
Iowa  99  11  11%  
Texas  1,114   123  11%  
Connecticut  50  5  10%  
District of Columbia  20  2  10%  
New Hampshire   20  2  10%  
Minnesota  131  12  9%  
     
              continued on next page  
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   18  
   
Table A-1: Home Health Agencies Cited With Condition-Level Deficiencies  
on Recertification Surveys Conducted by State Survey Agencies During  
Fiscal Years 201011 (Continued)  
Home Health  Agencies   Percentage of HHAs  
HHAs Cited With  
(HHA) Receiving a  Cited With 
State   Condition-Level  
Recertification Survey   Condition-Level  
Deficiencies (n=542) 
(n=5,210)   Deficiencies  
New Jersey   22  2  9%  
Utah  64  6  9%  
Arkansas  119  9  8%  
Kentucky  73  6  8%  
Illinois  287  21  7%  
Louisiana  105  7  7%  
Massachusetts  86  6  7%  
Georgia  64  4  6%  
Missouri  119  7  6%  
Wyoming  16  1  6%  
Oklahoma  108  5  5%  
Washington  22  1  5%  
New York   115  5  4%  
Tennessee  48  2  4%  
West Virginia   53  2  4%  
South Dakota   37  1  3%  
Virginia  104  3  3%  
South Carolina   48  1  2%  
Wisconsin  86  2  2%  
North Carolina   108  1  1%  
Pennsylvania  228  3  1%  
Alaska  11  0  0%  
Delaware  11   0  0%  
Hawaii  7   0  0%  
Maryland  18   0  0%  
Mississippi  26   0  0%  
Nebraska  52   0  0%  
North Dakota   14  0  0%  
Oregon  29  0  0%  
Rhode Island   4  0  0%  
Source:  Office of  Inspector General (OIG) analysis of Automated  Survey Processing Environments recertification  data for 
               
fiscal years 201011. 

 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)                19  
   
   
Table A-2: Home Health Agencies Cited With Condition-Level Deficiencies  
on Recertification Surveys Conducted by Accreditation Organizations  
During Fiscal Years 201011  
Home Health  Agencies   Percentage of HHAs  
HHAs Cited With  
Accreditation  (HHA) Receiving a  Cited With 
Condition-Level  
Organization   Recertification Survey   Condition-Level  
Deficiencies (n=210) 
(n=1,106)   Deficiencies  
The Joint Commission   480  159  33%  
Accreditation Commission 
142  13  9%  
for Health Care  
Community Health 
484  38  8%  
Accreditation Program  
Note: Each accreditation organization  uses its own survey instrument and methodology.  Although accreditation organizations must  
match their deficiency citations to those used by State agencies, a deficiency cited by an accreditation organization  may or may not 
correspond directly to a deficiency cited by a State agency.  
Source:  OIG analysis of recertification data from the Accrediting Organization System for Storing User Recorded Experiences for fiscal 
years 201011. 
 
   
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   20    
   
APPENDIX B 
Types of Complaints Lodged and Substantiated Against Home 
Health Agencies During Fiscal Years 201011 
Home Health  Agencies  (HHA)  
HHAs With Substantiated  
Complaint Description   With Complaints Lodged 
Complaints (n=842)  
Against Them (n=1,784)  
Quality of care/treatment   1,089   523 
Administration/personnel  665  312 
Patient rights  622  250 
Nursing services  370  156 
Admission, transfer, and discharge rights  286  124 
Other  228  111 
Falsification of records/reports   207  88 
Patient neglect  167  77 
Fraud/false billing  175  72 
Unqualified personnel  136  71 
Patient assessment  94  50 
Patient abuse  97  42 
Misappropriation of property  100  38 
Infection control  57  26 
Rehabilitation services   41  19 
Physician services  28  15 
Other services  32  11 
State licensure  7  4 
Accidents  8  3 
Quality of life   8  2 
Physical environment  10  2 
Pharmaceutical services  6  1 
Death  5  1 
Educational services  3  1 
State monitoring   2  1 
Restraints/seclusiongeneral  1  1 
No classification given  8  0 
Injury of unknown origin  5  0 
Note: Some complaints had more than one description and some HHAs had more than one  complaint; however, we counted each 
 
HHA only once for  each complaint description.  

Source:  Office of  Inspector General analysis of  complaints data from Automated Survey Processing Environments for fiscal  

years 2010-11. 

 
 
Home Health Agencies Received Timely Surveys and Corrected Deficiencies As Required (OEI-06-11-00400)   21    
   
APPENDIX C 
Agency Comments 
--
......
~ ..
(;T
DEPARTMENTOFHEALTH&HUMAN SERVICES Cen.ers lorMedicare &Medicaid Services
...
.(a-'-oI"#III AdminislTator
MAR 0 5 2013 Washlng.on. DC 2020'
DATE:
TO: Daniel R.Levinson
Inspector General
FROM: Marilyn TlN.enner
Acting ~dminislrator
SUBJECT: OfficeofInspectorGeneral(OIG)Draft Report: Home Health Agencies Received Timely
Surveys and Corrected Deficiencies as Required (OEI-06-11-00400)
Thank youfortheopportunity toreview andcomment ontheabove subject draftreport..TheCenters
forMedicare&MedicaidServices(eMS) appreciatestheextensiveworkdonebyOIGstaffinthe
developmentofthereport. eM isdedicatedtoitsresponsibilitytooverseethesurveysofhomehealth
agencies(HHAs)onatimelybasisandmakingsurealldeficienciesarecorrectedinordertoprotectthe
beneficiariesservedbytheseproviders. urveysofHHAsareconductedbybothstateagenciesand
approvedAccreditingOrganizations(AOs). Surveysincludeinitialcertifications,recertificationand
complaintsurveysaswellasvalidationsurveysofAOs. eMS recognizesthegrowthofHHAsandthe
risksposedtotheMedicareprogramandtheimportanceofcompliancewitheMS requirements. The
OIG sobjectives forthisstudyaretodetermine theextent towhich: (1)state survey agencies and
accreditation organizations conducted recertification surveys ofHHAs within required timeframes
during fiscalyears(FYs) 2010-11; (2)HHAs received deficiency citations onrecertification surveys
andthenature andresulting actions ofthose deficiencies during FYs2010-11; (3) HHAs had
complaints lodged (i.e.,allegations made) against them, thenature ofthose complaints, andthe
actions resulting fromthose complaints during FYs2010-11; and(4)eMS used "look-behind"
surveys toassess theperformance ofsurveyors during FYs2010-11.
TheOIGrecommendation andeMS response arediscussed below.
OIG Recommendation
TheOIGrecommends thateMS analyze survey datatodetermine whether itshould routinely
conduct look-behind surveys foroversight ofstate agencies.
CMS Response
TheeMS concurs with thisrecommendation. eMS isstriving tostrengthen our reviews ofHHAs in
avarietyofways. Anincrease inHHA look-behind survey activity would beaneffective tool inthis
effort. While look-behind activity inHHAs isnotstatutorily based, eMS's central office willwork
withourregional offices todevelop criteria thatwilltarget theneed forHHA look behind activity in
aparticular stateagency basedupon theagency's survey reports, totheextent possible within
existi.ngfiscalconstraints. CMS willalsoevaluate avariety ofotheroptions toassure effective look-
behindoversight ofSAperformance.
TheeMS looks forward toworking with OIGonthisandother issues inthe future.
 
Survey and Certification of Home Health Agencies in FY 2010-2011 (OEI-06-11-00400)   22   
   
ACKNOWLEDGMENTS 
This report was prepared under the direction of Kevin K. Golladay,  
Regional Inspector General for Evaluation and Inspections in the Dallas 
regional office; Blaine Collins, Deputy Regional Inspector General; and 
Ruth Ann Dorrill, Deputy Regional Inspector General.   
Jennifer Gist and Petra Nealy served as co-project leaders for this study.  
Central office staff who provided support include Berivan Demir Neubert, 
Sandy Khoury, and Christine Moritz.  
We would also like to acknowledge the contributions of other Office of 
Evaluation and Inspections regional office staff, including 
Leah K. Bostick. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Survey and Certification of Home Health Agencies in FY 2010-2011 (OEI-06-11-00400)   23   
Office of  Inspector General 
 
http://oig.hhs.gov  
 
The mission  of  the Office of Inspector General  (OIG), as mandated by  Public Law  95-452,  as  
amended, is  to protect the integrity of the Department of  Health and  Human Services  
(HHS) programs,  as  well as  the health  and  welfare of beneficiaries served by those  
programs.  This  statutory mission is carried out through a nationwide  network of  audits, 
investigations, and inspections conducted  by the  following  operating components:  
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The Office of  Audit Services (OAS) provides auditing services  for  HHS, either by conducting  
audits with its own audit  resources or  by overseeing  audit work done by  others.  Audits  
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HHS programs  and operations.  These assessments help reduce waste,  abuse, and  
mismanagement and promote economy  and efficiency throughout  HHS.  
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The  Office  of Evaluation and  Inspections (OEI)  conducts national evaluations to  provide  
HHS,  Congress,  and the public with  timely,  useful, and reliable information on  significant  
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The Office of  Investigations  (OI) conducts criminal, civil, and administrative investigations  
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by actively coordinating  with  the Department of  Justice and other Federal,  State,  and local  
law enforcement authorities.  The investigative efforts  of  OI often lead  to criminal 
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The Office of  Counsel  to the Inspector  General  (OCIG) provides general legal services  to 
OIG, rendering advice  and  opinions on  HHS programs and operations  and providing all  
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