[4034W] Operating Separate Entities in Texas HCSSA's | Structure, Implementation & Survey
Provides a detailed, Texas-specific roadmap for implementing and defending separate entities, including financial structuring, HR allocation, EMR configuration,
marketing differentiation, and quality reporting.
Presentation Info:
- TAHC&H Event | Monthly Member Webinars | Online On-Demand Access
- Presentation Date: March 10, 2026
Program Description:
A licensed & Medicare-certified home health or hospice agency may operate separate entities under one Texas Home and Community Support Services Agency (HCSSA) license.
However, merely declaring separate divisions is insufficient. Agencies must demonstrate operational, financial, clinical, and administrative separation during HHSC and CMS survey activities.
This program provides a detailed, Texas-specific roadmap for implementing and defending separate entities, including financial structuring, HR allocation, EMR configuration,
marketing differentiation, and quality reporting. You will learn how surveyors evaluate compliance and how to avoid common structural failures—particularly in light of All-Payer OASIS requirements.
After completion of this session, you will be able to:
- Define separate entities under Texas HCSSA licensure and distinguish them from branches, alternate delivery sites, and separate legal entities.
- Identify the operational components required to demonstrate true separation, including financial accounting, HR allocation, clinical documentation, EMR configuration, marketing, and quality reporting.
- Describe the specific documentation surveyors review to determine compliance, including governing body minutes, payroll allocation records, client census reports, and division-specific policies.
- Explain how staff interviews, record reviews, and observational findings are used by HHSC and CMS to validate or invalidate separate entity status.
- Develop an implementation plan for establishing or strengthening separate entities in preparation for All-Payer OASIS enforcement and regulatory review.
HCSSA Topic(s) Addressed:
- §558.259[c][2]information on the state and federal laws applicable to an agency
- §558.259[d][4] agency responsibilities
- §558.260[a][3] basic principles of management in a licensed health-related setting
- §558.260[a][6]risk assessment and management
- §558.260[a][7]financial management
Education-Training Credits:
- TX HCSSA Administrator/Alternate Continuing Education
- Continuing Education for Nurses
- 1.5 Contact Hr(s)
- This program awards CNE until 03.10.2028
Texas HCSSA CE Approval Statement
This program meets continuing education requirements for Administrators and Alternates under Texas HCSSA licensing regulations.
Nurse CE Approval Statement
Texas Association for Home Care & Hospice is an approved provider of continuing nursing education by Louisiana State Nurses Association,
an accredited approver by the American Nurses Credentialing Center's Commission on Accreditation. LSNA Provider No. 4002151
Requirements for Successful Completion:
To receive continuing education credits for this online presentation, the participant must view the entire online presentation, complete an evaluation, and post-test attestation.
Reporting of Perceived Bias:
Bias, as defined by the American Nurses Credentialing Center's Commission on Accreditation (ANCC COA/LSNA) is the tendency or inclination to cause partiality, favoritism, or influence.
Commercial bias may occur when a CNE activity promotes one or more product(s) (drugs, devices, services, software, hardware, etc.). This definition is not all inclusive and participants
may use their own interpretation in deciding if a presentation is biased. The ANCC COA is interested in the opinions and perceptions of participants at approved CNE activities,
especially in the presence of actual or perceived bias in continuing education. Therefore, ANCC invites participants to access their ANCC Accreditation Feedback Line to report any noted
bias or conflict of interest in the education activity.
The toll-free number is 1(866) 262-9730.
TAHC&H Faculty/Presenter(s):
Rosalind J. Nelson-Gamblin, Consultant, RJNG Health Care Consulting, LLC
About the Presenter(s): Rosalind J. Nelson-Gamblin
Rosalind has been a public speaker and facilitator for home care and hospice since 2000. In August 2022, Rosalind retired from a 33-year career in state government ending at
Texas Health and Human Services, where she was a senior policy specialist for regulation of long-term care including hospice, home health, and personal care,
supportive palliative care, assisted living, and day activity and health services industries. As a health care consultant, Rosalind is passionate about
assisting entity leaders to understand and overcome compliance challenges while advocating for quality of life and quality of care for clients, residents,
and patients. She continues to analyze state and federal legislation for impact to providers and consumers, review state regulations, develop and deliver
continuing education and training to providers, and provide guidance to industry leaders through state and federal survey preparation activities, such as
mock surveys and leadership mentoring. Rosalind is a subject matter expert for federal/nationwide standards and possesses a keen understanding of
accreditation for home health and hospice care. Rosalind is well-versed in the regulations for the settings where home care is delivered,
including nursing/skilled nursing, assisted living, intermediate care for individuals with developmental disabilities, and independent
living settings. She serves on the Board of Directors for the Texas ~ New Mexico Hospice and Palliative Care Organization.
She is an avid gamer, loves comics and reading, and resides in Austin with her husband, son, and cats.
[4034W] Operating Separate Entities in Texas HCSSA's | Structure, Implementation & Survey
