Certified Home Health Agency (CHHA) Standards and Accreditation Requirements

A Certified Home Health Agency — CHHA in shorthand — sits at a specific intersection of federal regulation and clinical accountability that most people don't think about until they're suddenly very glad it exists. These agencies are the ones authorized to bill Medicare and Medicaid for skilled home health services, which means they operate under a more rigorous compliance framework than unlicensed or purely private-pay providers. This page covers what CHHA certification actually requires, how the accreditation process works in practice, and where the distinctions between certified and non-certified agencies matter most for patients and families.

Definition and scope

A Certified Home Health Agency is a home health organization that has met the Conditions of Participation (CoPs) established under Title 18 of the Social Security Act and administered by the Centers for Medicare & Medicaid Services (CMS CoPs for Home Health Agencies, 42 CFR Part 484). Meeting these conditions is not optional for agencies that want to receive federal reimbursement — it is the threshold requirement.

The scope of services a CHHA is permitted to deliver is defined partly by state licensure and partly by the federal CoPs. At minimum, a certified agency must provide — or arrange for — skilled nursing care and at least one therapeutic service, such as physical therapy at home, occupational therapy, or speech therapy. Agencies that only provide personal care and custodial services — bathing assistance, meal prep, companionship — generally do not qualify as CHHAs and cannot bill Medicare for those services under the home health benefit.

The distinction matters enormously when comparing home care costs and financing options: Medicare-covered skilled home health is zero out-of-pocket for eligible beneficiaries under specific conditions, while non-certified aide services are almost entirely private pay or Medicaid-funded through waiver programs.

How it works

CHHA certification follows a defined sequence:

1. State survey: The state health department (or its contracted agent) conducts an on-site inspection to assess compliance with all applicable CoPs. Surveyors review clinical records, interview staff and patients, and observe care delivery directly.
2. Federal approval: CMS reviews the survey findings. If deficiencies are identified, the agency must submit and implement a Plan of Correction before certification is granted or renewed.
3. Accreditation (optional but substantive): Agencies may seek accreditation from a CMS-approved accrediting organization — The Joint Commission, CHAP (Community Health Accreditation Partner), or ACHC (Accreditation Commission for Health Care) — which grants "deemed status," meaning the accreditation survey substitutes for the state survey process. Deemed status does not eliminate state oversight entirely; states retain complaint investigation authority.
4. Ongoing compliance: Certified agencies are subject to recertification surveys on a roughly 36-month cycle, plus unannounced complaint-driven surveys at any time.

The 2017 revision to the Home Health CoPs (effective January 2018) significantly expanded requirements around patient-centered care planning, infection control, and quality assessment. Under the revised rules, every patient must have a written care plan developed by a registered nurse or therapist within 30 days of admission, with documented coordination among all disciplines involved in care.

Home care assessments and care plans are now a specific regulatory artifact — not just a clinical best practice — for any CHHA billing Medicare.

Common scenarios

Post-hospitalization transitions: The most common point of entry into CHHA services. A patient discharged after a hip replacement, cardiac event, or stroke is evaluated for home health eligibility. If a physician certifies that the patient is homebound and requires skilled care, a CHHA becomes the appropriate provider. Transitioning from hospital to home care involves specific referral and intake procedures that certified agencies are required to follow, including completing the Outcome and Assessment Information Set (OASIS) — a standardized data collection tool mandated by CMS for all Medicare/Medicaid home health admissions.

Chronic disease management: Patients with conditions like congestive heart failure or COPD may qualify for recurring CHHA episodes when their condition involves skilled nursing for medication management, wound care, or monitoring. Home care for chronic conditions under a CHHA framework is distinct from long-term supportive care — episodes are time-limited and goal-oriented.

Pediatric and specialty populations: CHHAs serving pediatric home care patients operate under the same federal CoPs but may face additional state-level requirements for staff training and specialized equipment.

Decision boundaries

The central question families face: does a particular situation call for a CHHA specifically, or will a non-certified home care agency serve the need equally well?

CHHA is specifically required when:
- Medicare or Medicaid reimbursement is expected for skilled services
- The care plan involves wound care, IV therapy, skilled observation, or post-surgical monitoring
- A physician has certified homebound status and ordered skilled home health services

A non-certified agency may be appropriate when:
- The primary need is companionship, housekeeping, or personal care without skilled clinical components
- The family is paying privately and does not require Medicare billing
- The patient is enrolled in a long-term care insurance plan that covers custodial care directly

The accreditation status of a CHHA — whether surveyed by the state alone or via a deemed-status accreditor like CHAP or The Joint Commission — does not change the services it can bill Medicare for. What accreditation does signal is a commitment to structured quality review beyond the minimum regulatory floor. Home care agency licensing and accreditation varies by state, and 12 states require CHHAs to hold licensure independent of federal certification, adding another layer of oversight that families can verify before selecting a provider.