■ Fifteen percent of HHAs repeated the same deficiency citation on three consecutive surveys. These cyclically deficient HHAs’ most frequently repeated deficiency citation is related to patient plans of care. On the three most recent surveys, these HHAs received, on average, twice as many deficiency citations per survey compared to HHAs that did not repeat citations. Among cyclically deficient HHAs, most are located in six States and tend to be concentrated in highly populated areas.
■ CMS oversight of HHAs could be improved. Currently, CMS does not use all available deficiency history information in its oversight of HHAs. We found that deficiency history beyond the most recent survey can be an important indicator of performance on the next survey and can improve CMS’s identification of at-risk HHAs. For HHAs with one or more condition-level deficiencies, CMS has no sanction other than initiating a termination track.