Templates

Vendor contract compliance checklist for home health and hospice (free)

When a surveyor asks for your contracted services, the question isn't just whether you have a contract. It's whether the contract says what the Conditions of Participation require: who keeps responsibility, who authorizes services, and that the contractor isn't excluded.

This checklist puts those items in one place. It covers every vendor contract, physician and referral source arrangements, home health services under arrangement, and hospice arranged services, inpatient care and nursing facility agreements. Each item names the rule it comes from.

Use one copy per contract. Mark each item Done, Missing, Partly or N/A, and note where in the contract it's covered. The counts at the top tell you what's left.

Download the checklist (free; Excel, works in Google Sheets and Numbers)

What to watch

Does the agreement keep responsibility with you?

Home health agencies must keep overall responsibility for services under arrangement, and hospices must keep administrative and financial management and oversight. The contract should say so.

Has the contractor been checked for exclusion?

Home health rules bar contractors that were excluded, revoked or debarred, and Medicare won't pay for services from an excluded party. Check the OIG list and SAM.gov before signing and on a schedule.

Is a physician or referral source paid at fair market value, set in advance?

The Anti-Kickback safe harbor and the Stark exception both expect a signed agreement of at least a year, with pay set in advance and not tied to referrals.

Does a nursing facility agreement cover the nine required items?

Hospice agreements with SNFs, NFs and ICF/IIDs must spell out communication, notifications, who decides the course of care, abuse reporting within 24 hours and bereavement services for staff.