Medical Records Impact Home Care Survey Outcomes
By: Becky Tolson, RN, BS, Manager, Survey Operations
Early in Becky Tolson’s nursing career, she focused on providing infusion services to patients in their homes. This experience in home-based care led to consulting roles in which she supported new agencies in establishing operational best practices. At ACHC, she supports surveyors across all home care programs. Becky is in demand as an educator at industry conferences and leads ACHCU webinars for providers seeking accreditation guidance.
Posted: February 1, 2026
Maintaining complete, accurate, and accessible medical records for the defined retention period is a foundational responsibility for home care agencies. Providing records to a surveyor promptly is a critical part of the ACHC Home Care Accreditation survey process and a core expectation for home care agencies.
Surveyors need access to requested records to effectively assess the safety, consistency, and continuity of patient care. Medical records serve as a primary source of evidence to evaluate an organization’s practices, quality of care, and adherence to accreditation standards and internal agency policies. Delays, incomplete documentation, or an inability to retrieve records promptly may result in survey findings.
When a surveyor asks to review current or closed records, the goal is to assess care delivery, identify patterns, or validate corrective actions. When records cannot be produced upon request, the surveyor’s ability to evaluate compliance is hindered, and concerns about record organization, retention practices, or system reliability may arise. Even when care has been appropriately delivered, the inability to show it through accessible documentation may indicate compliance gaps due to ineffective record management processes.
Record retention
Medical record retention is governed by the agency’s policies and procedures as well as state requirements, if any exist. These policies and procedures must be clearly defined, consistently applied, communicated to staff, and fully implemented. Record retention is not merely an administrative function. It is an essential operational and risk management responsibility that supports continuity of care, survey readiness, and organizational accountability.
Following a change in ownership, responsibility for medical record retention and accessibility transfers to the new owner. Medical records created prior to the ownership change remain part of the legal medical record and must be kept per the agency’s established policies and procedures and any applicable state requirements.
The organization must ensure these records are readily retrievable and available to ACHC Surveyors upon request, regardless of storage method, location, or prior vendor arrangements. Failure to maintain continuity of access to records from a prior owner may indicate gaps in governance and oversight and may result in survey findings.
Similarly, when an organization transitions to a new medical record system—including a change in EMR—the responsibility for maintaining access to all records created in the previous system continues. Records maintained in legacy systems must remain secure, intact, and retrievable for the duration of the agency’s retention period. Inability to retrieve closed records during a survey may raise concerns about record retention practices and system planning.
From an operational and risk management perspective, proper medical record retention and accessibility are essential. Records may be needed years after services are provided to respond to complaints, audits, or legal matters. Ensuring that records remain secure, confidential, and accessible throughout the retention period supports effective oversight and reduces organizational risk.
In summary, home care agencies must define and follow clear medical record retention policies, incorporate applicable state requirements, and ensure records are available to surveyors at all times. By prioritizing timely access, consistent retention practices, and strong record governance, organizations demonstrate survey readiness, accountability, and a commitment to high-quality home care services.
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