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Understanding Deemed vs. Non-Deemed Accreditation Surveys with CHAP

Whether you’re a small single-site provider or a large national organization, understanding the differences between a Deemed vs. Non-Deemed Accreditation survey can help you make an informed decision that best suits your organization’s needs.

What is CHAP?

The Community Health Accreditation Partner (CHAP) is an independent, nonprofit accrediting body for home and community-based healthcare organizations. CHAP accreditation demonstrates that an organization meets the industry’s highest standards of excellence.

Deemed Accreditation Surveys

What Does “Deemed Status” Mean?

  • Deemed status refers to the authority granted by the Centers for Medicare & Medicaid Services (CMS) to accrediting organizations like CHAP.
  • When CHAP conducts a deemed accreditation survey, CMS accepts CHAP’s findings in lieu of its own survey by a state survey agency. In some states, CHAP may conduct the state licensure survey in conjunction with the deemed accreditation survey.
  • Achieving deemed status means your organization is compliant with the Medicare Conditions of Participation (CoPs).

Benefits of Deemed Surveys

  1. Regulatory Compliance: Satisfies CMS requirements, allowing you to participate in Medicare and Medicaid programs.
  2. Efficiency: Eliminates the need for separate CMS surveys, saving time and resources.
  3. Credibility: Enhances your organization’s reputation for meeting nationally recognized standards.

Considerations

  • Scope: Deemed surveys are comprehensive, covering all CMS regulatory requirements.
  • Preparation: Requires thorough readiness to meet both CHAP standards and CMS regulations.

Non-Deemed Accreditation Surveys

What Are Non-Deemed Surveys?

  • Non-deemed surveys are accreditation evaluations that do not grant deemed status with CMS.
  • Suitable for organizations not seeking participation in Medicare or Medicaid programs. and for Medicare-certified agencies who choose to receive Medicare certification through the state survey agency. 

Considerations

  • Limitations: Does not fulfill CMS requirements; separate CMS surveys may still be necessary.
  • Recognition: May not carry the same weight in terms of national credibility.
  • Strategic Fit: Best suited for organizations with specific operational scopes.

Context for Different Provider Sizes

Small Single-Site, Single-Service Providers

  • Deemed Surveys: Beneficial if you plan to bill Medicare or Medicaid. However, the preparation and cost might be significant for smaller operations.

Mid-Level Multi-Site, Multi-State Providers

  • Deemed Surveys: Provides a consistent standard across all locations, simplifying compliance management. Essential if you’re expanding services that require Medicare or Medicaid billing.
  • Non-Deemed Surveys: Could be used selectively for sites not involved with CMS/Medicare. This option may appeal to providers operating a mix of service lines. For instance, you might have some branches functioning as home health agencies (Medicare-certified, skilled care) and others operating as home care agencies (non-Medicare, often private pay or custodial services).
    • It’s important to note the distinction:
      • Home Health typically involves skilled nursing or therapy services and must adhere to CMS regulations if participating in Medicare.
      • Home Care generally focuses on non-medical support—such as personal care, companionship, and assistance with daily living activities—and often doesn’t require Medicare participation.
      • If you’re considering non-deemed accreditation for your home health operations, reviewing CHAP’s home care standards may be helpful. 

Large National Providers

  • Deemed Surveys: Highly beneficial for streamlining operations and ensuring all sites meet federal requirements. Enhances national credibility and trust.
  • Non-Deemed Surveys: Can be used in conjunction with deemed surveys to optimize resources. Since large providers often have compliance officers and teams, a combination of both might be best for comprehensive compliance and efficient use of resources.
    • Combination Approach: Leveraging both deemed and non-deemed surveys can allow large organizations to tailor accreditation efforts based on specific site needs and services offered.
    • Compliance Management: With dedicated compliance teams, large providers can effectively manage the complexities of both survey types.

Making the Decision

Questions to Consider

  1. Are you billing or planning to bill Medicare or Medicaid?
    • If yes, a deemed survey is necessary. Some states allow services to be provided without deemed status when billing Medicaid (for example personal care or continuous skilled nursing). Each state has its own requirements. 
  2. What is the strategic goal of accreditation for your organization?
    • Is it regulatory compliance, quality improvement, or both?
  3. Do you have a compliance team to manage accreditation processes?

Next Steps

  • Assess Your Needs: Align your choice with your operational goals and regulatory requirements.
  • Consult with CHAP: Engage with CHAP representatives to understand the specifics and get guidance tailored to your organization.
  • Review CMS Guidelines: Visit the CMS website for detailed information on Medicare participation requirements.

Choosing between deemed and non-deemed accreditation surveys with CHAP depends on your organization’s size, services, and strategic goals. Deemed surveys offer the advantage of meeting CMS regulatory requirements and are essential for those involved with Medicare and Medicaid. 

By understanding these differences and considering your organization’s specific context, you can make an informed decision that supports your mission to provide excellent community-based healthcare.