The medical record review includes  determining whether the HHA has a current and appropriate plan of care  for each patient as ordered by the patient’s physician, whether the ordered  care and services are provided and coordinated by the personnel who  furnish them, and whether the patient’s physician is notified of changes in  medical condition. Weaknesses in Survey Process and Inconsistencies in How States Conduct Surveys Mask Potential Quality Problems

Shortcomings in the HHA survey process as well as inconsistencies in how  states conduct surveys make it difficult to assess the quality of care  provided. In addition, surveyors did not always conduct on-site  revisits to ensure that the COP deficiencies identified had been corrected. Although CMS requires HHAs with a good  survey track record to be surveyed every 3 years, some must be surveyed  annually, such as those with COP-level deficiencies and those with 3 or  fewer years in the Medicare program and thus little practical experience in  providing home health services. This could present a gap in state oversight  with respect to complaints, since they may be filed directly with an HHA  rather than with the state. Moreover, CMS oversight of state activities is too limited to identify the  significant problems we have reported. We are sending copies of this report to the Secretary of Health and Human  Services and to the Administrator, Centers for Medicare and Medicaid  Services. V) and indicate that serious quality  problems are likely understated.
What GAO Found

The 6,900 Home Health Agencies (HHAs) that serve Medicare beneficiaries must meet federal requirements, known as conditions of participation (COP), to ensure that they have the appropriate staff, are following the plan of care specified by a physician, maintain medical records to document the care provided, and periodically reassess each patient's condition. Although nationwide surveys done at HHAs since 1998 have identified a small proportion of agencies with serious deficiencies, the extent of the problem may be understated, and dangerous situations affecting home health patients may occur more often than documented. Shortcomings in the survey process and inconsistencies in state surveys make it difficult to assess the quality of care delivered and may mask potential problems. The ability to lodge complaints about an HHA and have them resolved promptly is important to protecting patient health and safety. HHA oversight by the Centers for Medicare and Medicaid Services (CMS) has been too limited to identify the problems GAO found in the survey process. CMS does not review state compliance with requirements for conducting HHA surveys, such as whether HHAs with COP-level deficiencies are surveyed annually rather than every 3 years or whether minimum patient visit and medical record review samples are adhered to.