Who we serve · Home Health & Hospice (HCSSA)
Workplace Violence Prevention for Home Health & Hospice (HCSSA)
Home & community support services agencies (HCSSAs) — licensed and certified home health and hospice providers — are covered under Texas Health & Safety Code Chapter 331 when they employ two or more registered nurses. HHSC applied the mandate through Provider Letter PL 2024-10 (Revised), with the same September 1, 2024 deadline, and defines an employed RN as a current license in a W-2 relationship regardless of job duties.
Home health and hospice risk is a field-environment risk: lone clinicians entering patients’ homes, unpredictable household conditions, and travel between visits. A fixed-worksite plan does not fit. VIGILO builds a program around lone-worker exposure, pre-visit risk screening, and field response protocols.
Where the mandate applies
How Chapter 331 reaches your setting
- A home & community support services agency (HCSSA) — home health or hospice — is covered under HSC Chapter 331 if it employs two or more registered nurses, applied through HHSC Provider Letter PL 2024-10 (Revised).
- PL 2024-10 defines an employed RN as a current RN license in a W-2 relationship, regardless of job duties — administrative RNs count toward the two-RN trigger.
- The same September 1, 2024 compliance deadline applies; compliance is checked at the licensure survey.
- The risk is a field-environment risk — lone clinicians in patients’ homes, unpredictable settings, and travel — so the plan must address lone-worker exposure, not a fixed worksite.
- Chapter 331 has no fine schedule; enforcement is a licensure-survey deficiency plus post-incident litigation discovery.
Speaking the language of surveyors
The six questions a surveyor will ask — answered
Surveyors follow a tracer: they pull the thread from policy to plan to committee to training to record to corrective action. This module is organized around exactly what they ask, what they review, and what gets a facility cited.
What surveyors ask
- Do you employ two or more RNs — the trigger that brings an HCSSA into scope under PL 2024-10?
- Have you confirmed covered status using the PL 2024-10 definition of an employed RN (current license plus a W-2 relationship, regardless of job duties)?
- Does your plan address the field environment — lone clinicians in patients’ homes, unpredictable settings, and travel between visits — not just a fixed worksite?
- Is your committee properly composed, including a registered nurse who provides direct patient care?
- Is training delivered at least annually to a distributed, often-remote workforce, and did you complete the annual plan evaluation to your governing body?
What surveyors review
- Confirmation of covered status under PL 2024-10 (the two-employed-RN trigger).
- A plan addressing the home and field environment — lone-worker risk, patient-home conditions, and travel.
- Committee charter, roster (confirming the required direct-care RN), and minutes.
- Training rosters across a distributed field workforce, including make-up records.
- The annual plan evaluation report to the governing body.
Required documentation
| Document | Why surveyors want it |
|---|---|
| Covered-status determination (PL 2024-10) | Documents the two-employed-RN trigger; W-2 + current license |
| Field-environment written plan | Lone clinicians in homes, unpredictable settings, travel risk |
| WVP committee charter + RN-direct-care member | Must reflect direct patient care |
| Annual training records (distributed workforce) | Field staff reached at least annually, with make-up tracking |
| Annual plan evaluation to governing body | Statutory recurring obligation under Ch. 331 / PL 2024-10 |
Common deficiencies
- Assuming an HCSSA is exempt when it employs two or more RNs — a direct misread of the PL 2024-10 trigger.
- Miscounting employed RNs by job duties rather than the W-2-plus-current-license definition PL 2024-10 sets.
- A plan written for a fixed worksite that ignores lone-worker and patient-home risk in the field.
- Training that cannot reach a distributed field workforce, leaving gaps in the annual record.
- The annual governing-body evaluation skipped.
How to prepare
- Count employed RNs by the PL 2024-10 definition (current license + W-2) and document the covered-status determination.
- Build the plan around the field environment — lone-worker protocols, pre-visit risk screening, check-in procedures, and travel.
- Compose a committee with the required direct-care RN and set its meeting cadence.
- Create a training delivery and make-up process that reaches remote field staff at least annually.
- Calendar the annual evaluation and report it to your governing body.
How VIGILO helps
VIGILO builds a home-health and hospice program for the field environment — through the WVP Foundation Package and the Annual Compliance Subscription:
- A covered-status determination using the PL 2024-10 employed-RN definition, documented for your file.
- A facility-specific written plan addressing lone-worker, patient-home, and travel risk — not a fixed-worksite template.
- A compliant committee charter with the required direct-care RN, plus facilitation and minutes.
- Annual and orientation training, English and Spanish, with a make-up process built for a distributed field workforce.
- The annual plan evaluation prepared and documented to your governing body — every year.
Texas SB 240 compliance
See the full statute breakdown, the covered-facilities matrix, and the implementing rules on our Texas SB 240 compliance hub.
Recommended path
Audit → Foundation → Annual program of record
Survey-Readiness Audit
A scored gap report against the Chapter 331 / 26 TAC §133.55 / PL 2024-10 / Joint Commission checklist.
Flat fee · $500–$1,500
Details →Workplace Violence Prevention Programs
The complete, facility-specific program of record — committee, plan, training, and binder.
Flat fee · $2,500–$6,000
Details →De-Escalation Training
Bilingual (English / Spanish) de-escalation and threat-response training for clinical settings.
$1,500–$2,500 / training day
Details →Serving every covered healthcare facility class across Texas. See all settings we serve →
Home Health & Hospice (HCSSA) compliance FAQ
Frequently asked questions
Are home health and hospice agencies covered by Texas Chapter 331?
A home & community support services agency (HCSSA) — licensed and certified home health or hospice — is covered by HSC Chapter 331 if it employs two or more registered nurses. HHSC applied the mandate to HCSSAs through Provider Letter PL 2024-10 (Revised), with the same September 1, 2024 compliance deadline. A covered agency must maintain a committee, written plan, at-least-annual training, a confidential anti-retaliation reporting policy, post-incident response, and an annual plan evaluation reported to the governing body.
How does PL 2024-10 define an “employed RN” for the two-RN trigger?
Provider Letter PL 2024-10 clarifies that an employed RN means a person holding a current RN license in a W-2 employment relationship with the agency, regardless of job duties. That means RNs in administrative or non-direct-care roles still count toward the two-RN threshold. Miscounting by job duties is a common way agencies misjudge their covered status.
How is a home health workplace violence plan different from a hospital plan?
Home health and hospice risk is a field-environment risk: lone clinicians entering patients’ homes, unpredictable household conditions, animals and weapons, and travel between visits. A fixed-worksite hospital plan does not address lone-worker exposure. A defensible HCSSA plan includes pre-visit risk screening, check-in procedures, and field-specific response protocols.
Is VIGILO a security or escort service for home health clinicians?
No. VIGILO provides compliance, training, and consulting only — we build and document your WVP program and train your field staff in de-escalation and lone-worker safety. We do not provide security guard, escort, patrol, or investigative services and do not guarantee safety outcomes.
Would your home health & hospice (hcssa) program hold up under survey?
A Survey-Readiness Audit scores your committee, plan, training, and governing-body reporting against Chapter 331, the Joint Commission, and OSHA — in one document.