Certificate of Need & Home Health Agency Application Assistance

Certificate of Need & Home Health Agency Application Assistance

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Get help in submitting your CON & HHA application

Our team will walk you through submitting your certificate of need and home health agency application.

Knowing the right documents to submit, which applications to submit, and ensuring they are filled out correctly is one of our specialties. It can feel quite daunting to have to fill out these applications alone. Hire us today to help you fill these out and review it for accuracy. Please note that we have no power to approve these, so the approval or denial is out of our control. But you can be sure that we will do our best to help you ensure you are putting your best foot forward. Also note 3rd party fees such as submission fees and notary fees are not included. Additionally policies and procedures creation is a separate service not included in this fee.


-> Assisting you in filling out the proper paperwork, answering pertinent questions regarding the application, and reviewing it prior to submission.

Don't go for this alone. Get help in the CON & HHA application process, We can review your application, assist in filling it out, and provide recommendations and assist you in reminding you of important timelines related to your Home Health Agency application.


States have different requirements, applications, etc. But here are some example applications, information, and requirements for Maryland & Washington, D.C.:

Home Health Agency

Here is the link to the Home Health Agency information: https://dchealth.dc.gov/node/173032


Here is an example of the Home Health Applications form we assist with - https://dchealth.dc.gov/node/173052


Home Health DC Application: https://dchealth.dc.gov/sites/default/files/dc/sites/doh/publication/attachments/Application%20for%20Home%20Care%20Agency%20Licensure.pdf

Home Health Maryland Application: https://health.maryland.gov/ohcq/ac/Ambulatory%20Images/Instructions%20Home%20Health.pdf


Here are the steps to follow to get the Home Health Agency live: https://dchealth.dc.gov/sites/default/files/dc/sites/doh/publication/attachments/Procedures%20to%20Obtain%20a%20License%20to%20Operate%20a%20Home%20Care%20Agency%202016.pdf

Certificate of Need

If you have been accredited and been a Residential Service Agency (RSA) for 3 years we can help with your CON application.

Before obtaining a license from OHCQ to operate a Home Health Agency, organizations have to obtain a Certificate of Need (CON) from the Maryland Health Care Commission. (https://mhcc.maryland.gov/mhcc/Pages/hcfs/hcfs_con/hcfs_con_applications.aspx)

To submit the CON, Non-existing home health service providers need to be currently licensed and accredited, in good standing, as a hospital, a nursing home or a Maryland residential service agency (RSA) providing skilled nursing services, and proposing to establish a new HHA in Maryland.

Here is the source documenting the need for 3 years: "Maryland Residential Service Agency (RSA) Applicants may qualify to apply for a CON to establish an HHA in Maryland by demonstrating a track record in providing good quality of care. This is achieved by documenting it has operated and provided skilled nursing services for at least three years, has established a system for collecting data that includes systematic collection of process, outcome and experience of care measures, and has maintained accreditation through a deeming authority recognized by Maryland’s Department of Health and Mental Hygiene for at least the three most recent years of operation, consistent with COMAR RSA applicants must submit data to the Commission to document ability to monitor the required quality measures and performance levels. Data requirements are outlined in Appendix D." - https://mhcc.maryland.gov/mhcc/pages/hcfs/hcfs_con/documents/chcf_con_hha_guidelines_20161114.pdf

The reason you may want to apply to switch from a RSA to a Home Health Agencies (HHA) is Home Health Agencies may also be able bill Medicare. But prior to that it needs the CON, PECOS registration, & state inspection. 



Overall certificate of need information:


Certification of need steps information:



Certification of need application itself: https://dchealth.dc.gov/sites/default/files/dc/sites/doh/publication/attachments/Certificate_of_Need_Application_N.pdf

Regulations / time frames of CON (P.9): https://dchealth.dc.gov/sites/default/files/dc/sites/doh/publication/attachments/SHPDA_Statutes.pdf

Additional regulations, information on letter of intent etc.:



CON submission batch dates

Home Health Services: Review Period Begins: April-October

Recommended Submission of Application: March 20th September 20th: https://dchealth.dc.gov/sites/default/files/dc/sites/doh/publication/attachments/Certificate%20_of_Need_Schedule_of-Reviews_2.pdf

Please note the fee for the CON is: “the greater of 3% of the proposed capital expenditure or $5,000, with a maximum of $300,000.” (P.19) https://dchealth.dc.gov/sites/default/files/dc/sites/doh/publication/attachments/SHPDA_Statutes.pdf

Getting Accepted is extremely difficult - We cannot guarantee success. But we can help you put your best foot forward.


As noted here the 2017 Health Systems plan noted that the then 38 Home Health Agencies were sufficient (P.89). This will make it exceedingly difficult to get approved for a CON in DC. As they basically are saying they don’t need more of them.


Page 104 really shows how tough it would be as it clearly recommends that there is no need for additional home health agencies stating

“Distribution and capacity are not the leading concerns for post-acute care services.

• The discharge distribution of DC hospitals mirrors national and state trends; most patients are discharged to the home with no post-acute services.”


Thus the main aspect of Need meaning Demand is already starting in a tough situation. So even with our assistance this is a really difficult undertaking. But we will do our best to help you.


As it states that “applications contain clear and convincing evidence that the proposed project meets each of the six criteria defined in this section, including:

  1. Need
  2. Accessibility
  3. Quality
  4. Acceptability
  5. Continuity and Coordination of Care
  6. Financial Impact

The burden of demonstrating ability to achieve each of these criteria rests on the Applicants” (P.111).

We might be able to create a case that we will be aiming to fix the deficiencies, but they would need to know why can’t the current ones do those changes already, and how it may impact them. As if it is simply a different way of doing business, or different connections, or EHR implementations, or tools, the current ones can do that too.


Even if we suggest increasing capacity for a targeted area or demographic that wont fly. “While it is certainly possible that targeted efforts to expand capacity for certain geographic or demographic segments could enhance access and address some of the challenges that DC’s residents face, service capacity is not the dominant health system challenge” (P.110)


We will need to make a business case as to how our unique new business will “address challenges deemed to be central to strengthening DC’s health care system, such as:

• Underlying social determinants of health
• Engagement in appropriate care
• Coordination of care across service providers
• Integration of clinical and non-clinical services (particularly to address the burden of behavioral health)
• Organizational collaboration/partnership
• Implementation of evidence-informed protocols/services to address disparities (particularly related to the management of chronic or complex health conditions)
• Administrative barriers related to insurance coverage and access to care/services
• Health literacy, health education, and prevention” (P.111).


The approach would need to deal with the root causes pointed out such as:

“(1) poor communication between patients, family members, caregivers, and patients’ clinical and non-clinical service providers,
(2) poor coordination, lack of teamwork, and lack of direct accountability for who is responsible for managing the care transition process,
(3) inadequate amount of time and lack of standardized procedures regarding the initial care transition hand-off,
(5) lack of patient education and health literacy,
(6) conflicting or confusing medication regimens, and
(7) unclear instructions about follow-up care. Efforts need to be made to identify the underlying issues related to poor care transitions. A Districtwide assessment conducted collaboratively could promote a collective understanding of these issues and promote collaboration” (P.96).

We would need to do something using their expected evidence based solution of “multi-sector collaborations and community partnerships” (P.96). Such as policies/protocols regarding “patient follow-up with their primary care provider and other specialty medical care providers are critical to a full recovery and to avoiding inappropriate hospital readmissions” (P.96). Or some sort of EHR solution that would be very different from what is currently being used.

To do that, we would need to research and provide proof / support for our method from the sources provided on page 112 and 113, or peer review journals. Which is basically a research project and thinking how to turn it into a clear business case. But as stated above it is still so tough to answer their requirement 3 of NEED on page “Explain why current providers cannot meet the need for services by: a. Describing the existing service landscape for the proposed service area, including existing providers, capacity, and services provided.”


Financial impact will be a tough aspect as well. As it states:

“• The financial viability of the D.C. health system as a whole. The growth or entrance of a new health care provider can also have a significant impact on existing providers in the market, either by duplicating or disrupting existing services or resources. While the SHPDA encourages innovation in the market that can lead to lower cost, better quality care, these benefits must justify and compensate for any negative impact on existing providers. A primary goal of CON oversight is to avoid unnecessary duplication of services.” (P.122) As they will say its duplicating what is already there, or stealing patients from them and causing them to have less.


But it is still doable if you have a good case and just need help in submission. Or if you want to do this process in another state.

Please note that to successfully be approved we will also need to be able to provide forecasts. This will be needed to provide a moving argument about the feasibility etc. To do this we need to “Provide information on the financial viability of the Applicant, such as audited financial statements.” (P.122).

So please note that it may be very tough to succeed in your certificate of need CON submission, but we can do our best to meet the requirements by clearly:

“• Demonstrate that there are patients who are having difficulty accessing care because of a shortage of providers.

  • Identify why existing providers cannot meet the demand for services.
  • Clearly define the scope and level of services and identify the target population.
  • Demonstrate how the quality of care will be consistent with CMS and DC licensing regulations, for Home Health Agencies participating in Medicare and Medicaid, include Home Health Compare (HHC) Star Ratings.
  • Demonstrate that the Applicant will be able to be accredited by appropriate accreditation agencies.
  • Clearly define the roles and responsibilities of personnel and identify the necessary qualifications and credentials required for the provision of high quality services.
  • Demonstrate their understanding and experience with the health care delivery system in the District in general and the underserved and minority groups in particular.
  • Demonstrate a track record, experience, and qualification in the provision of the proposed services. • Demonstrate the capacity to bill across a diverse payer base.
  • Demonstrate how continuity of care will be ensured” (P.131) https://publications.jsi.com/JSIInternet/Inc/Common/_download_pub.cfm?id=18290&lid=3

Please also note that as part of the CON you need to agree to provide uncompensated care for five (5) years for a particular eligibility criteria “Currently, CON holders are required to provide uncompensated care that is either equal to at least three percent of its operating expenses, not including reimbursement for Medicare and Medicaid, or as contractually obligated to the District of Columbia—whichever standard results in a higher dollar amount. D.C. Code §44-405(a); 22 DCMR 4400.2, 4404.1.” - https://www.communitycatalyst.org/initiatives-and-issues/initiatives/hospital-accountability-project/free-care/states/district-of-columbia


Here is a potential source of facts that can be cited:

Community Health Needs Assessment District of Columbia, 2019: http://www.dchealthmatters.org/content/sites/washingtondc/2019_DC_CHNA_FINAL.pdf

Also this looooong document is super helpful for ideas on how to use supporting evidence and make a case for a CON -


See p.125 for example


A cursory review of the approval findings of CON applications shows most establishing CON applications were denied. https://dchealth.dc.gov/sites/default/files/dc/sites/doh/publication/attachments/2017%20CON%20Decisions.pdf


The one approved called “VNA of Maryland d/b/a VNA of the District of Columbia” has been around a long time, and can therefore make a stronger case about its finances etc. As seen here VNA had been around since the 1960’s, were named national Homecare Elite List & Public Policy Advocate of the Year - https://www.medstarvna.org/about-us/history/

For assistance in submitting a CON and HHA application click add to cart NOW!


(Information provided is subject to change and should not be used for making decisions, it is for education purposes only. For personalized guidance feel free to reach out to us for a consultation.)