Deemed Status (Medicare Accreditation)
Last reviewed · By Chad Griffith
Deemed status is the recognition by CMS that a healthcare organization accredited by an approved accrediting organization (AO) has met the equivalent of CMS Conditions of Participation through accreditation. Deemed-status organizations are not subject to routine state surveys for CMS-mandated CoP compliance — accreditation is deemed sufficient. CMS approves accrediting organizations under 42 CFR 488 Subpart A: The Joint Commission, DNV Healthcare, HFAP (Healthcare Facilities Accreditation Program), AAAHC (Accreditation Association for Ambulatory Health Care), ACHC (Accreditation Commission for Health Care), CIHQ (Center for Improvement in Healthcare Quality), and others depending on provider type. State surveyors continue to perform complaint surveys and Life Safety Code surveys regardless of accreditation status.
Frequently Asked Questions
Which accrediting organizations have CMS approval?
Approval varies by provider type. For hospitals: The Joint Commission, DNV Healthcare USA, HFAP, CIHQ, and Center for Improvement in Healthcare Quality. For ASCs: Joint Commission, AAAHC, AAAASF (American Association for Accreditation of Ambulatory Surgery Facilities). For HHA: Joint Commission, ACHC, CHAP (Community Health Accreditation Partner). For hospices: Joint Commission, ACHC, CHAP. The complete list is published on the CMS Accreditation page and is updated when AOs gain or lose approval.
What is the benefit of deemed status?
Deemed status eliminates routine state surveys for CMS-mandated CoP compliance, reducing duplicative oversight burden. Accredited organizations are surveyed by their AO on the AO's cycle (typically every 3 years for triennial accreditation). Deemed status also provides a national standardized accreditation framework — particularly valuable for multi-state organizations seeking consistent operational standards. Many payers also recognize accreditation in their network credentialing processes.
Does deemed status eliminate all state surveys?
No. State surveyors continue to conduct: (1) complaint surveys triggered by complaints filed with the state survey agency; (2) Life Safety Code surveys on the LSC cycle; (3) validation surveys randomly conducted to verify the AO's deemed-status determination; (4) revisit surveys following deficiencies. State surveys for routine CoP compliance are eliminated — but specific-purpose surveys continue regardless of accreditation.
What happens if an organization loses accreditation?
Loss of accreditation triggers loss of deemed status. The organization must then either: (1) achieve accreditation by another CMS-approved AO; (2) undergo state surveys to demonstrate CoP compliance and continue Medicare participation through state survey/certification; or (3) lose Medicare participation. Loss of accreditation typically follows sustained non-compliance with the AO's standards — the underlying performance issues may also affect CMS state survey results, making the recovery path challenging.
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