A licensed & Medicare-certified home health or hospice agency may operate separate entities under one Texas Home and Community Support Services Agency (HCSSA) license. However, merely declaring separate divisions is insufficient. Agencies must demonstrate operational, financial, clinical, and administrative separation during HHSC and CMS survey activities.
This session provides a detailed, Texas-specific roadmap for implementing and defending separate entities, including financial structuring, HR allocation, EMR configuration, marketing differentiation, and quality reporting. Participants will learn how surveyors evaluate compliance and how to avoid common structural failures—particularly in light of All-Payer OASIS requirements.
After completion of this session, the participant will be able to:
- Define separate entities under Texas HCSSA licensure and distinguish them from branches, alternate delivery sites, and separate legal entities.
- Identify the operational components required to demonstrate true separation, including financial accounting, HR allocation, clinical documentation, EMR configuration, marketing, and quality reporting.
- Describe the specific documentation surveyors review to determine compliance, including governing body minutes, payroll allocation records, client census reports, and division-specific policies.
- Explain how staff interviews, record reviews, and observational findings are used by HHSC and CMS to validate or invalidate separate entity status.
- Develop an implementation plan for establishing or strengthening separate entities in preparation for All-Payer OASIS enforcement and regulatory review.
Faculty: Rosalind J. Nelson-Gamblin, Consultant, RJNG Health Care Consulting, LLC
Continuing Education: 1.5 clock hours continuing education for Administrators/Alternates; 1.5 contact hours Continuing Nursing Education
Each registration is for one (1) person only. You must pay for a separate registration for each person needing continuing education credits (CE’s).
Register: Online
Cost:
Members: $75
Non Members: $150
No refunds will be given.