How to Beat $21,000 Daily Healthcare Survey Penalties

Survey failures cost home health and hospice agencies an average of $5,000 per dependent survey, with immediate jeopardy violations triggering daily penalties up to $21,000, according to The Home Health Consultant. The October 2025 transition from HIS to HOPE assessments doubles penalty rates from 2% to 4% for agencies missing submission deadlines,CMS reports indicate. As regulatory pressure intensifies, agencies need practical solutions from experts who understand both clinical care and compliance requirements.

Dr. Tatevik Melkumyan represents a unique combination of medical expertise and operational knowledge that makes her the only consultant in Los Angeles equipped to address both clinical and administrative aspects of quality assurance. Trained as an endocrinologist and radiologist at Yerevan State Medical University, she moved to the US in 2018 and discovered that American healthcare agencies were failing surveys not due to poor patient care, but because of documentation and process gaps that could be systematically prevented. As the owner of NT QA Inc., she has developed a compliance methodology that several home health and hospice agencies credit with helping them avoid Medicare termination.

From Armenian Medical Practice to US Quality Consulting

Dr. Melkumyan spent four years as an endocrinologist in Armenia, treating patients with diabetes, thyroid disorders, and other hormone-related conditions. Her training included both endocrinology and radiology specializations, giving her experience with complex diagnostic procedures that required precise documentation standards.

When she moved to Los Angeles in 2018, her Armenian medical credentials required additional certification for US practice. While pursuing medical licensure, she took contract work helping healthcare agencies prepare for CMS surveys. What she discovered surprised her: excellent clinicians were failing inspections because they couldn’t translate their care into the documentation language that regulators expected to see.

“Many agencies struggle with passing surveys and keeping up with changing rules,” she explains. Her medical training taught her to look for patterns, and she began noticing the same mistakes appearing across different organizations. The problem wasn’t clinical competence – nurses and therapists were providing good patient care. The failures occurred because of specific gaps in CMS documentation requirements that most healthcare professionals never learn in their clinical training. For example, agencies would lose points for failing to document pain reassessment within the required timeframe after medication administration, even when pain was effectively managed. Or they’d receive citations for incomplete QAPI documentation when their actual quality improvement processes were working well but weren’t presented in the format surveyors expected to see.

This insight led her to develop what she calls “easy-to-follow checklists” that translate complex regulatory requirements into specific daily tasks. Her system includes chart review tools and step-by-step audit procedures that help agencies identify compliance gaps before surveyors arrive.

Systematic Approach to Survey Preparation

Dr. Melkumyan’s methodology addresses three critical areas where agencies typically fail: documentation consistency, staff training protocols, and ongoing quality monitoring systems. Her checklist approach ensures that nurses, therapists, and administrative staff understand exactly what needs to be documented and when those records must be completed.

“Many agencies have great nurses who provide excellent patient care, but they fail surveys because nobody taught them what surveyors actually look for in the charts,” she explains. “My system breaks down every requirement into simple daily tasks, so staff don’t have to guess what’s needed.”

The training component solves a persistent industry problem: high staff turnover means agencies constantly onboard new employees who may not understand compliance requirements. Her materials include orientation modules and refresher training programs that maintain consistency despite personnel changes.

For quality monitoring, she created internal audit tools that agencies can use between official surveys. These tools help identify patterns in documentation gaps or process failures that could trigger violations during CMS inspections. Rather than waiting for external surveyors to find problems, agencies using her system catch issues early and implement corrections.

Her approach proved particularly valuable during recent regulatory changes. Several agencies using her methodology successfully navigated the transition from paper-based to electronic health records without survey violations, while similar organizations struggled with documentation requirements in the new systems.

Preparing for the HOPE Transition Challenge

The upcoming HOPE transition presents even greater challenges. The current Hospice Item Set (HIS) requires documentation at only two points: admission and discharge. HOPE (Hospice Outcomes & Patient Evaluation) expands this to four assessment points within the first 30 days alone, plus discharge documentation. More significantly, HIS focused on process measures – whether certain activities were completed. HOPE shifts to outcome measures, tracking how well symptoms are managed and whether patient goals are achieved.

“Most agencies don’t realize that HOPE isn’t just more documentation – it’s completely different documentation,” Dr. Melkumyan explains. “HIS was essentially a checklist: did you assess pain, did you discuss preferences. HOPE requires ongoing clinical evaluation and reassessment. You need workflows that support continuous monitoring, not just initial assessments.”

The change affects staffing patterns as well. Under HIS, agencies could batch documentation tasks. HOPE’s multiple timepoints require clinical staff to integrate assessment activities into regular care visits, fundamentally changing how care teams organize their time.

How Medical Associations Recognize Her Compliance Expertise

Dr. Melkumyan maintains active membership in the National Association for Healthcare Quality, reflecting her standing among compliance professionals. Her continued participation in the European Society of Endocrinology and Armenian Association of Pediatric Endocrinologists demonstrates her ongoing clinical credentials, while her planned membership in the California Medical Association indicates her commitment to returning to direct patient care.

Healthcare professionals regularly refer colleagues to implement her quality systems, creating a network effect that extends her influence beyond direct client relationships. This peer recognition has led to formal recommendations for leadership roles and project involvement within healthcare organizations throughout California.

Her educational materials have become standard resources for staff onboarding in multiple home health and hospice agencies. The materials circulate through professional networks, expanding their use beyond her immediate client base. Agency administrators credit these resources with reducing training time while improving staff confidence during survey preparation.

The practical value of her work is evidenced by client retention patterns. Agencies that implement her system typically continue working with NT QA INC for ongoing compliance support, indicating sustained satisfaction with results.

From 23-Day Termination Threats to Full Compliance Success

The compliance consulting market in California includes dozens of firms offering survey preparation services, but few combine clinical expertise with operational knowledge. Dr. Melkumyan’s medical background gives her insight into documentation requirements that purely administrative consultants often miss.

Her client base includes agencies across Southern California, from small hospice providers to larger home health organizations. One recent case involved a hospice that received immediate jeopardy citations for medication management documentation gaps. The agency faced potential Medicare termination within 23 days unless violations were corrected.

“During COVID, agencies were panicking about new infection control rules,” Dr. Melkumyan recalls. “I created emergency checklists that showed exactly how to document infection prevention measures. Within two weeks, my clients went from worried to confident about their survey readiness.”

The home health market continues expanding rapidly, with industry projections showing growth from $311.66 billion in 2024 to $719.31 billion by 2035. This growth creates opportunities for quality consultants, but also increases regulatory scrutiny as more agencies enter the market.

“The HOPE transition will catch most agencies off guard because it requires four assessment points instead of two,” she notes. “Agencies using my system already have workflows in place that can handle the increased documentation load. Others will be scrambling in October.”

Dr. Melkumyan plans to expand NT QA INC services to other states as demand grows, though she currently focuses on California agencies. The challenge lies in adapting her methodology to different state-level requirements while maintaining the clinical perspective that differentiates her approach from standard compliance consulting.