The four required on arrival
- A client list for each licensed category of service
- The client record of every client admitted before the survey
- All agency policies Chapter 558 requires
- All personnel records
Texas · Initial survey · 26 TAC §558.501-.527
The Texas HCSSA initial survey: what surveyors check
Within six months of your license, you admit a first client and ask HHSC to survey you. The surveyor then arrives unannounced, visits at least three homes and reviews your policies, client records and personnel files. Here is the whole process, and the ten things Texas agencies are cited for most.
- Rule-verified September 30, 2026
- Quoted from 26 TAC Chapter 558
- HHSC FY 2025 citation data
Quick answer
The initial survey is HHSC’s first on-site inspection of a new Texas home care agency. You ask for it: no later than six months after the license date, a PAS agency must admit and serve at least one client, then send HHSC Form 2020, Notification of Readiness for Initial Survey.
The survey itself is unannounced. On arrival the surveyor expects your client list, the record of every client admitted so far, all the policies Chapter 558 requires and all personnel records. The surveyor makes at least three home visits, then gives preliminary findings at an exit conference. Written findings follow within 10 working days, and you then have 10 days to send a plan of correction.
The most-cited violation at Texas home health agency inspections in FY 2025 was failing to let a surveyor in within two hours, with 146 citations.
From license to survey, step by step
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Admit and serve your first client
After licensingYou cannot admit anyone until the license is issued. A PAS-only agency then needs at least one client admitted and served before it can ask for the survey.
26 TAC §558.521(b)(1)Send HHSC Form 2020
Within 6 months of the license dateSend Form 2020, Notification of Readiness for Initial Survey, to your designated survey office. List each client’s name, admission date and category of service.
26 TAC §558.521(a), (c)The surveyor arrives unannounced
Any business dayHHSC does not give notice. If you are closed during business hours, the administrator, alternate or a designated representative must let the surveyor in within two hours.
26 TAC §558.505, §558.523(e)Entrance conference
The surveyor explains the survey and takes questions. For an initial survey, the administrator or alternate must be there in person.
26 TAC §558.523(a), §558.525(a)Home visits and record review
The surveyor makes at least three home visits, reviews your records and checks each standard. A record stored somewhere else must reach the surveyor within eight working hours.
26 TAC §558.525(b), §558.507(c)Exit conference
The surveyor gives preliminary findings. The administrator or alternate must be there in person. If you want to send more evidence, describe it now and send it within two working days.
26 TAC §558.527(a), (d)Written findings, then your plan of correction
10 + 10 daysHHSC sends written findings within 10 working days. You have 10 days from receiving them to send a plan of correction for each violation, even if you disagree.
26 TAC §558.527(f), (g)(3), (i)
What must be ready when the surveyor walks in
26 TAC §558.521(d) lists four things that must be "available and ready for review by a surveyor upon the surveyor's arrival". The other rules on surveys add a few more.
The rest of the survey rules
- A written designation of who can let a surveyor in
- The administrator or alternate, in person, at the entrance and exit conferences
- A reasonable and safe workspace for the surveyor
- Records kept elsewhere delivered within 8 working hours of a request
Refusing to cooperate is treated harshly: "HHSC may assess an administrative penalty without an opportunity to correct", or deny, revoke or suspend the license (26 TAC §558.507(i)).
The 10 most-cited violations, and the policy that covers each
HHSC publishes the Chapter 558 violations it cites most often at home health agency inspections. In FY 2025 the top ten alone added up to 842 citations. Nearly all of them are about a written system that was missing or not followed: survey entry, registry rechecks, abuse reporting, quality meetings, training and personnel files.
1. Not letting a surveyor in within two hours, or no designated person to do it
1462. Missing the yearly nurse aide and misconduct registry recheck
1013. Abuse, neglect or exploitation not reported within 24 hours
924. No QAPI program, or one not implemented and reviewed
855. Administrator or alternate missing 12 hours of yearly continuing education
806. Not letting HHSC in to survey
777. Personnel files without proof of licenses, references, experience or education
708. QAPI committee not meeting at least twice a year
689. PAS client files without a complete individualized service plan
6210. Personnel files without performance evaluations and disciplinary actions
61
Source: HHSC Regulatory Services Annual Report FY 2025, Top 10 Violations Cited During Inspections: Home Health Agencies, pp. 158-159.
| # | HHSC’s wording | Rule | Manual policy |
|---|---|---|---|
| 1 | "The agency failed to provide a surveyor entry to the agency to begin a survey within two hours of when notified of the surveyor’s arrival during regular business hours ..." | §558.523(e) | 1.4 Surveyor entry and survey cooperation1.1 Operating hours and closed-office notice |
| 2 | "The agency failed, after the initial verification of employability, to search the nurse aide and employee misconduct registries at least every 12 months ..." | §558.247(a)(5)(B) | 3.3 Criminal history checks and registry searches |
| 3 | "The agency failed to immediately report within 24 hours, knowledge of an alleged act of abuse, neglect, or exploitation of a client by an agency employee, contractor, or volunteer ..." | §558.249(c) | 6.1 Reporting abuse, neglect and exploitation |
| 4 | "The agency failed to have, implement, and review a quality assessment and performance improvement program consistent with state requirements." | §558.287(a)(1) | 9.1 Quality assessment and performance improvement (QAPI) |
| 5 | "The agency’s administrator or alternate administrator failed to complete 12 hours of continuing education ..." | §558.260(a) | 4.2 Administrator training and continuing education |
| 6 | "The agency did not allow HHSC to go into and survey the agency to find out if the agency follows state licensing laws and rules." | §558.507(a) | 1.4 Surveyor entry and survey cooperation |
| 7 | "The agency failed to include verification of license, permits, reference(s), job experience, or educational requirements to verify qualifications for each position a person accepted in its personnel records." | §558.246(a)(3) | 3.2 Personnel records |
| 8 | "The agency failed to make sure its quality assessment and performance improvement committee met at least twice a year to address identified problems and concerns in service delivery." | §558.287(c) | 9.1 Quality assessment and performance improvement (QAPI) |
| 9 | "The agency failed to make sure the files of clients receiving personal assistance services included a properly developed individualized service plan that had all the required elements." | §558.404(f)(2) | 5.1 Individualized service plan |
| 10 | "The agency failed to include performance evaluations and disciplinary actions in its personnel records." | §558.246(a)(4) | 3.2 Personnel records |
A policy on its own does not stop a citation; the surveyor checks that you did what it says. What a good policy does is spell out who does what, by when, and what record proves it, so the yearly registry recheck or the twice-yearly QAPI meeting is on someone’s calendar. HHSC surveys for the new SEMARC registry search from October 6, 2026, so check your background-check process covers it.
After the survey: findings, plan of correction and disputes
HHSC sends official written findings within 10 working days after the exit conference. They list any violations and explain how to submit a plan of correction and how to request informal dispute resolution (IDR).
You must send an acceptable plan of correction for each violation no later than 10 days after you receive the findings. A plan of correction says what you will change and by when. If HHSC rejects it, you get one more chance, within 30 days of the rejection notice. You must send one even if you disagree: the rule says so explicitly.
Each violation also has a deadline for actually fixing it, set by its severity:
| Violation | Correct it |
|---|---|
| Level B: serious harm or death, or a serious threat to client health or safety | Address on receipt, correct within 2 days |
| Level B: substantially limits your capacity to provide care | Within 7 days of the written notice |
| Level A: minor or no health or safety significance | Within 20 days of the written notice |
| Not given a severity level | Within 60 days of the date cited |
Disputing a finding
To dispute a violation, mail or fax HHSC’s IDR request form within 10 days of receiving the findings, then make sure your rebuttal letter and evidence reach the Survey and Certification Enforcement Unit within seven days of that. Copy everything to your survey office. HHSC will not grant IDR for a violation cited at your previous survey and cited again with no new findings, and a plan of correction does not stop HHSC taking enforcement action.
Accreditation instead of an HHSC survey
An agency accredited for its services by an HHSC-approved accreditation organization is exempt from HHSC surveys, except for the investigation of complaints. The rule names three: the Joint Commission, the Community Health Accreditation Partner (CHAP) and the Accreditation Commission for Health Care (ACHC).
To use it, send the accreditation documents to your HHSC survey office no later than six months after the license date, instead of Form 2020. If accreditation comes through after you have asked for a survey, you can still send the documents before the surveyor arrives. The rules also require the accreditation documents to be available at any survey.
Proposed · not in force
What the proposed 2026 rules change
The six-month deadline runs even if you have no Medicaid or payer contract yet, and HHSC may take enforcement action if you serve no client in six months. The proposed text says: "The agency must submit the letter of readiness within six months, regardless of the agency’s ability to obtain payer source authorization or secure a contract for services." Comments close on October 19, 2026.
Read the full rule-change guide →Frequently asked questions
When does the Texas HCSSA initial survey happen?
After you ask for it. Within six months of the license date, a PAS agency must admit and serve at least one client and send HHSC Form 2020, Notification of Readiness for Initial Survey. HHSC then arrives unannounced.
Does HHSC tell you when the surveyor is coming?
No. 26 TAC §558.505 says HHSC does not announce or give prior notice of a survey. If you are closed during business hours, someone you have designated in writing must let the surveyor in within two hours.
What does the surveyor look at?
Your client list, the records of every client admitted before the survey, all policies Chapter 558 requires and all personnel records. The surveyor also makes at least three home visits.
Do I need a client before the survey?
Yes. A PAS-only agency must admit and provide services to at least one client before requesting the initial survey, and list that client on Form 2020.
What happens if I miss the six-month deadline?
HHSC may deny renewal of the initial license, or revoke or suspend it, and an initial license cannot be renewed without an initial survey unless the agency is accredited.
What if the surveyor cites a violation I disagree with?
Send a plan of correction anyway, within 10 days of receiving the findings; the rules require it even if you disagree. You can also request informal dispute resolution (IDR) within 10 days, unless the same violation was cited at your previous survey with no new findings.
Can accreditation replace the HHSC survey?
Yes, except for complaint investigations. Accreditation from the Joint Commission, CHAP or ACHC exempts you from HHSC surveys. Send the accreditation documents to your survey office within six months of the license date instead of asking for a survey.
How often is an agency surveyed after that?
HHSC may survey again within 18 months of the initial survey, and must survey on site at least every 36 months after that.
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Keep reading
Texas
How to start a home care agency in Texas
License, fees, training and the initial survey.
Texas
Every policy Chapter 558 requires
The full rule-to-policy map for a PAS agency.
Texas
Running your agency from home
The four conditions, including surveyor entry.
Texas
The proposed Chapter 558 rewrite
What changes and how to comment.
Sources
- 26 TAC Chapter 558, Licensing Standards for Home and Community Support Services Agencies · Texas HHSC (text via Cornell LII) · retrieved September 30, 2026
- Texas Health and Safety Code Chapter 142 · Texas Legislature · retrieved September 30, 2026
- HCSSA Frequently Asked Questions (updated July 2026) · Texas HHSC · retrieved September 30, 2026
- Provider Letter PL 2026-10: Search Engine for Multi-Agency Reportable Conduct (SEMARC) · Texas HHSC · retrieved September 30, 2026
- Regulatory Services Annual Report FY 2025 · Texas HHSC · retrieved September 30, 2026
- Proposed Rules, 26 TAC Chapter 558 (rule project 22R045), 51 TexReg 6429, September 18, 2026 · Texas Register · retrieved September 30, 2026