What topics must a Texas HCSSA policy manual cover?

Under 26 TAC Chapter 558, a Texas HCSSA policy manual must address at minimum: scope of services, client rights and responsibilities, admission and discharge procedures, care coordination and service planning, caregiver orientation and ongoing training, supervision of personnel, emergency preparedness, infection control, incident reporting (including abuse, neglect, and exploitation), record-keeping and documentation, client grievances, financial and billing arrangements, and personnel policies including hiring and background checks. Agencies providing medication management or skilled nursing must add policies specific to those service lines.

How often must I review and update my HCSSA policy manual?

At minimum, annually. Texas HHSC requires agencies to review their policy manual at least once every 12 months and to update any policy that no longer reflects current operations, staffing, or regulatory requirements. The review must be documented — a signed acknowledgment by the administrator with the date of review. A manual with no documented annual review is one of the most commonly cited policy deficiencies during periodic HHSC surveys.

Do all employees need to read and sign the policy manual?

Yes. Under 26 TAC Chapter 558, HCSSA agencies must conduct a new-employee orientation before staff begin providing services to clients, and that orientation must include a review of the agency's policies and procedures. Each employee must sign an acknowledgment confirming they received the orientation and reviewed the policies. Those signed acknowledgments must be filed in the employee's personnel record and are reviewed by HHSC surveyors during every survey.

What happens at survey if my policies and procedures are incomplete?

An incomplete or outdated policy manual generates deficiencies under 26 TAC Chapter 558. Depending on severity, deficiencies may require a Plan of Correction within 10 calendar days and a follow-up survey visit before your license is confirmed. Multiple policy deficiencies at an initial survey can extend your license timeline by 30 to 60 days. Policies that exist on paper but don't match actual agency operations are treated as seriously as missing policies — surveyors verify policy compliance through staff interviews and record reviews.

Texas HCSSA Policies and Procedures Requirements 2026: Complete Checklist for New Agencies

Most new HCSSA agency owners treat the policy manual as something to pull together in the week before their initial survey. That approach can work — but only if the manual that emerges from that week is actually complete. The problem is that "complete" under Texas HHSC standards covers more ground than most owners realize, and the gap between a rough policy manual and a survey-ready one is exactly where initial survey deficiencies cluster.

This guide covers every policy and procedure requirement for a Texas HCSSA Personal Assistance Services agency: the required topic areas, what each policy must address, the annual review obligation, staff training documentation, and what HHSC surveyors look for when they review your manual. All information reflects the current requirements under 26 TAC Chapter 558 as of October 2026.

Why Policies and Procedures Are a License Requirement, Not a Formality

Under Texas law, written policies and procedures are not administrative best practices — they are regulatory requirements. An HCSSA agency cannot pass its initial HHSC survey, and cannot receive a full license, without a written policy manual that covers the required topics under 26 TAC Chapter 558.

The policy manual serves two functions in HHSC's regulatory framework:

First, it defines how your agency intends to operate. HHSC surveyors evaluate your agency by comparing what your policies say against what your agency actually does. If a policy exists but the agency's records show it isn't being followed, that gap is a deficiency. If a required policy area is missing entirely, that is also a deficiency.

Second, it protects your clients. Client rights, grievance procedures, incident reporting, and emergency protocols all depend on documented policies that every staff member has reviewed and agreed to follow. An agency that can't show its employees were trained on these policies can't demonstrate it is actively protecting the clients it serves.

The HCSSA Pre-Survey CBT — which all applicants must complete before submitting a license application — devotes a dedicated module to policies and procedures. HHSC includes it because this is consistently an area where new agencies arrive underprepared.

When Your Policy Manual Must Be Ready

Your policy manual must be in place before your initial HHSC survey — not after you receive your license, and not in draft form at survey time.

A complete application does not guarantee an immediate survey date. HHSC schedules initial surveys after confirming application completeness. But once that date is set, every required policy must be in final written form, reviewed and signed by your designated administrator, and consistent with how your agency actually plans to operate.

That last part matters: policies that describe a staffing structure you haven't established, supervision protocols you haven't implemented, or training programs you haven't yet scheduled are inconsistent with actual operations — a common deficiency pathway that is entirely preventable with early preparation.

Build your policy manual before you begin hiring or scheduling clients. Policies written before operations begin give you a framework to hire against, a reference for caregiver orientation, and an audit trail showing your agency's operations were deliberate from day one.

Required Policy Topic Areas Under 26 TAC Chapter 558

The following topic areas are required for agencies licensed to provide Personal Assistance Services (PAS). Agencies with a Licensed Home Health or other HCSSA category have additional service-line requirements.

1. Scope of Services

Your agency must have a written policy describing the services it is licensed and staffed to provide: personal care, homemaker, companion, respite, and escort. The policy should also identify services the agency does not provide, the geographic service area, and the populations the agency serves.

A well-written scope policy prevents service creep — caregivers agreeing to tasks beyond the agency's PAS authorization because a client or family member asked — and helps surveyors quickly identify whether the agency's operations are within its licensed scope.

2. Client Rights and Responsibilities

Every HCSSA must maintain a written client rights policy describing the rights clients hold under Texas law: privacy and confidentiality, dignity and respectful treatment, the right to refuse any service, the right to participate in care planning decisions, the right to file a complaint without fear of retaliation, and the right to be informed of any changes to their services or rates.

The policy must specify what clients receive in writing before services begin — the formal Client Rights statement — and how delivery of that statement is documented. It should also describe client and family responsibilities: communicating schedule changes, maintaining a safe home environment for caregivers, and identifying an emergency contact.

HHSC's complaint hotline — 1-800-458-9858 — must be made available to clients and families and is typically included in the written Client Rights statement given at admission.

3. Admission, Discharge, and Transfer

This policy governs how clients enter and exit your agency's services. Required elements:

Assessment process at intake (confirming the client's needs are within the PAS scope)
Criteria that would result in discharge — for example, client needs that exceed what PAS services can safely address
Required notice to clients and families before planned discharge (the timeframe and form of notice)
Documentation requirements for any service termination
How the agency coordinates with other providers when a transfer or referral is appropriate

Discharge without documentation and proper client notification is a consistently cited survey deficiency, particularly when a client's condition changed and the agency stopped service without recording the clinical or safety basis for the decision.

4. Care Coordination and Service Planning

Your agency must document how each client's service plan is developed, maintained, and communicated to caregivers. For a PAS agency, this includes:

How the initial service plan is created at intake (who completes it and what it must include)
How often the plan is reviewed for accuracy
Who is authorized to modify the service plan
How changes are communicated to assigned caregivers before the next visit

The service plan is the operational document that defines what a caregiver does on each visit. A policy that doesn't describe how plans are created and updated creates a documentation gap that surveyors will find when they pull client files.

5. Caregiver Orientation and Ongoing Training

HHSC requires all agency personnel to complete orientation training before they begin providing services to clients. Your orientation policy must describe:

What topics are covered in new-employee orientation (this should include policies and procedures, client rights, incident reporting, emergency protocols, EVV clock-in procedures, and infection control)
Who is responsible for conducting orientation
Documentation generated (sign-in sheets, signed policy acknowledgments)
How competency is verified before a caregiver works independently with clients

Your ongoing training policy must describe how caregivers complete required continuing training throughout their employment and how that training is documented in their personnel file.

For a complete breakdown of Texas's caregiver training requirements by service type, the Texas Caregiver Training Requirements 2026 guide covers the specific topics, hours, and documentation requirements.

6. Supervision of Personnel

HCSSA agencies must have a written policy governing how they supervise caregivers. The supervision policy must specify:

The frequency of supervisory contacts (the policy must state a specific frequency — not "as needed")
What form supervisory contacts take (in-home visits, telephone check-ins, GPS-verified scheduling review)
Who conducts supervisory activities — typically the administrator, alternate administrator, or a designated supervisor
How supervisory contacts are documented (personnel file entries, supervision logs)
How the agency responds when a caregiver performance issue is identified during supervision

The single most important detail: your supervision policy must match your actual practice. If the policy states monthly in-home supervisory visits but your records show visits occurring quarterly, that inconsistency is a survey deficiency — regardless of whether the actual visits were adequate. Write the supervision policy to describe what your agency can actually sustain operationally, then execute it consistently.

7. Emergency Preparedness

Texas HHSC requires every HCSSA agency to have a written emergency preparedness policy describing how the agency will continue to protect and serve clients during emergencies. Required elements:

Client prioritization: Which clients are most vulnerable during a disruption; how the agency prioritizes outreach and checks during declared emergencies
Staff communication: How the agency reaches caregivers when normal communication channels are disrupted; backup contact methods
Backup service arrangements: How the agency ensures client coverage when a scheduled caregiver cannot reach a client due to an emergency
Coordination with local emergency management: The agency's process for aligning with local disaster declarations that affect service delivery

Texas-specific planning considerations:

Coastal and Gulf region agencies: Hurricane evacuation and multi-day power outage protocols
All Texas agencies: Winter storm preparedness (Winter Storm Uri in February 2021 caused statewide grid failures affecting all regions — agencies that had emergency staffing plans responded faster than those that did not)
Urban agencies: Heat emergency protocols during extreme heat advisories affecting elderly and disabled clients

The emergency preparedness policy must be reviewed and updated annually, and all staff must receive orientation training on emergency procedures. Atlas Care Software's Nora Coverage Rescue — which automatically identifies and fills open shifts — directly supports emergency staffing policies by ensuring coverage continues even when the primary caregiver cannot make a shift.

8. Infection Prevention and Control

Your infection control policy must address how caregivers prevent transmission of communicable diseases during home visits. Required elements include:

Hand hygiene requirements (when and method)
Personal protective equipment (PPE) availability and correct use
What caregivers must do before a shift if they are experiencing illness symptoms
Proper disposal of waste materials generated during care
Cleaning procedures for any equipment used in the client's home

Since 2020, HHSC surveyors have paid closer attention to infection control policies during surveys. Policies should reference current CDC guidance and should include the policy update date so surveyors can see the guidance is current.

9. Incident Reporting

HCSSA agencies must have a written incident reporting policy that addresses how incidents — including abuse, neglect, and exploitation (ANE) — are handled internally, reported to HHSC, and referred to state authorities.

Required elements:

Definitions: What constitutes a reportable incident; how ANE is defined under Texas law
Internal reporting chain: Who a caregiver reports an incident to and within what timeframe
External reporting obligations: Mandatory reporter requirements — for ANE in a home care setting, reports go to HHSC's Complaint and Incident Intake (1-800-458-9858) and to DFPS (1-800-252-5400 or txabusehotline.org)
Documentation: What is recorded in the client file after an incident
Non-retaliation: Employees who report in good faith must not face adverse employment consequences

Failure to report ANE within the required 24-hour window is the single most frequently cited HCSSA survey deficiency according to HHSC's published FY2023 data. Your incident reporting policy must make the external reporting obligation and timeline explicit — not implicit in the policy language. The Texas HCSSA Survey Preparation Guide covers the 24-hour reporting window and documentation requirements in detail.

10. Record-Keeping and Documentation

Your record-keeping policy must address what the agency maintains, how long records are kept, and how they are protected. Under 26 TAC §558.301, client records must be complete, accurate, organized, and accessible at the agency's principal place of business.

Key elements:

Client records: What is maintained in each client file (service agreement, initial assessment, service plan, visit records, incident reports, billing documentation, consent forms)
Employee records: What is maintained in each personnel file (application, background check results, training and orientation records, TB results, credential documentation)
Storage and access: Electronic records systems are acceptable under HHSC policy; records must be immediately retrievable during a survey
Retention: Client records must be retained for a minimum of five years following the client's discharge date; records for minor clients must be retained longer (consult current HHSC guidance for the applicable period)
Destruction: Confidential records must be destroyed in a manner that protects client privacy

The record-keeping policy is the framework that makes your supervision, training, and incident policies verifiable during a survey. Without documented records, the best operational policy is invisible to a surveyor.

11. Client Grievances

Your grievance policy must describe the process by which clients or their representatives can raise a complaint about the agency's services and how the agency responds. Required elements:

How and when clients are informed of the grievance process (typically included in the Client Rights statement at admission)
The timeframe for the agency to acknowledge and resolve grievances
How grievances are documented internally
HHSC's complaint hotline (1-800-458-9858) as an alternative avenue for clients who prefer to file externally
Non-retaliation: clients who file grievances must not have services reduced or terminated in response

The grievance policy connects directly to your client rights policy — it describes the mechanism through which clients exercise their right to complain.

12. Financial Arrangements and Billing

For private pay agencies, the financial policy must describe:

How service rates are communicated to clients before services begin
What the service agreement includes regarding payment terms and billing frequency
How the agency handles rate changes (advance notice to clients)
The agency's policy on overdue accounts

Your financial policy should cross-reference your service agreement template. Surveyors expect that what the policy says about billing aligns with what the agency's service agreements actually require of clients.

13. Personnel Policies

Your personnel policy section must address the full employment lifecycle: hiring criteria, background check requirements, disciplinary process, and termination. Core elements:

Minimum hiring qualifications for each position
Criminal history check requirements for all new hires before client contact (DPS Chapter 250 fingerprint check, SEMARC EMR and NAR review, OIG exclusion check for Medicaid-funded clients)
TB testing requirement for new hires
Job descriptions documenting the responsibilities of each role
Disciplinary procedures for policy violations, including a progressive discipline framework
Termination procedures ensuring that former employees no longer have access to client information or scheduling systems

The background check requirements for Texas HCSSA agencies — including the August 2026 SEMARC transition from the standalone EMR portal — are covered in the Texas Home Care Background Check Requirements 2026 guide.

The Annual Review Requirement

Your policy manual is not a one-time submission document. Under 26 TAC Chapter 558, HCSSA agencies must review their policy manual at least annually and update any policy that no longer reflects current operations, regulatory guidance, or HHSC requirements.

The review must be documented. Best practice: a signed review acknowledgment from the designated administrator that records the date of review, whether any policies were revised, and the administrator's signature. Keep this in the policy manual binder or your policy management system.

During periodic surveys, surveyors will ask when the last policy review occurred. A manual with outdated revision dates and no review documentation is a deficiency — it signals that the agency is not actively managing its compliance posture.

Triggers that require an out-of-cycle policy update:

A regulatory change under 26 TAC Chapter 558 (HHSC publishes amendments in the Texas Register; significant changes are typically addressed in Policy Letters)
A change in the agency's service offerings, geographic area, or staffing structure
A pattern of incidents or client complaints that reveals a gap in current policies
An HHSC survey deficiency citing a specific policy inadequacy
Any change in Texas mandatory reporting requirements or background check procedures

The designated administrator is responsible for maintaining the policy manual. This is one of the administrator's core compliance obligations under 26 TAC Chapter 558 — see the Texas HCSSA Administrator Requirements 2026 guide for the full scope of the administrator's compliance responsibilities.

Staff Training and Acknowledgment Documentation

Every HCSSA employee — caregivers, the administrator, office staff — must receive new-employee orientation that includes a review of the agency's policies and procedures before they begin working with clients. This is a requirement under 26 TAC Chapter 558, not an optional onboarding practice.

At the conclusion of orientation, each employee must sign an acknowledgment form confirming:

They attended the orientation
They received and reviewed the agency's policies and procedures
They understand their obligations under those policies

Signed acknowledgments belong in the employee's personnel file. During every survey — initial, periodic, or complaint-initiated — HHSC surveyors review a sample of personnel files. Missing orientation acknowledgments are consistently among the top deficiencies cited.

When policies are updated following an annual review, you do not need to re-orient all existing staff. However, if a policy change is significant enough to affect caregiver conduct with clients — a change to incident reporting procedures, supervision protocols, or infection control practices — documenting that staff were briefed on the change is both good practice and protection against a future deficiency finding.

Common Policy Deficiencies That Cause Survey Problems

Understanding what generates deficiencies lets you audit your manual before the surveyor does.

Missing required topic areas. The most direct deficiency: a required policy area is absent from the manual. This typically happens when an agency uses a generic policy template that wasn't written specifically against Texas 26 TAC Chapter 558 requirements — topics like supervision frequency, EVV documentation, or the specific Texas ANE reporting obligations are often missing in non-Texas-specific templates.

Policies that don't match actual operations. A supervision policy describing monthly in-home visits, but visit logs showing quarterly contact. An infection control policy requiring PPE for every visit, but no PPE supplies purchased. These gaps are discovered through record review and staff interviews — both are part of every HCSSA survey. Write policies that describe what your agency can actually sustain and then sustain them.

Outdated policies. A manual with a revision date from two or three years prior, no documented annual review, and content referencing regulations or procedures that have since changed. Surveyors read policy update dates. An outdated manual suggests the agency isn't actively managing compliance.

Missing employee acknowledgment records. Personnel files without signed orientation acknowledgments, particularly for staff hired within the past 12 months. For new agencies, this is nearly always a risk if orientation paperwork wasn't handled rigorously from the first hire.

ANE reporting policy gaps. The single most-cited HCSSA deficiency involves ANE reporting. A policy that doesn't specify the 24-hour reporting window, doesn't identify HHSC and DFPS as required reporting recipients, or doesn't address non-retaliation for staff who report in good faith is incomplete — and incident reporting deficiencies carry serious consequences.

Policy language copied from a home health template. PAS and Licensed Home Health have different requirements. A PAS agency operating with a home health policy manual — one that references RN supervision requirements, skilled nursing protocols, or Medicare billing procedures — will generate deficiencies from the mismatch between the license category and the policies.

How Your Scheduling Software Supports Policy Compliance

Several of the required policy areas above — supervision, training, incident reporting, and emergency staffing — require ongoing documentation to prove the policy is being followed operationally. Written policies describe intent; records prove execution.

Atlas Care Software supports documentation compliance in concrete ways:

GPS-verified visit records create the audit trail your supervision and documentation policies require — every completed visit is timestamped, location-verified, and retained in the system
Nora's Credential Guardian tracks training expiration dates and sends automatic reminders before credentials lapse, keeping your personnel records current without manual calendar management
Supervisory visits can be scheduled in Atlas as a distinct shift type alongside client-facing visits, so supervisory activity is documented alongside clinical operations in the same system
Nora's Coverage Rescue automatically fills open shifts when a caregiver calls out — directly supporting the emergency staffing and backup coverage requirements in your emergency preparedness policy
Client visit documentation generates the visit-by-visit records that support your care coordination and record-keeping policies

These aren't replacements for a well-written policy manual — they're the operational systems that generate the records your policies promise. The gap that creates survey deficiencies is rarely a bad policy; it's good policies with no documentation evidence that they were actually followed.

For agencies evaluating whether their current software generates the documentation depth HHSC surveys require, the comparison pages on /compare cover how Atlas and other Texas-used platforms handle EVV verification, visit documentation, and caregiver credential tracking.

Before Your Initial Survey: Policy Readiness Checklist

Use this to audit your policy manual before your survey date:

Related Resources for Texas HCSSA Agencies

Texas HCSSA Licensing Guide — four license categories, administrator qualifications, document checklist, and 60–90 day PAS processing timeline
Texas HCSSA Survey Preparation 2026 — what surveyors review in each of the six survey areas; Plan of Correction requirements
Texas HCSSA Administrator Requirements 2026 — administrator qualifications, initial training hours, continuing education, and the alternate administrator role
Texas Home Care Caregiver Training Requirements 2026 — required orientation topics, ongoing training hours, and documentation standards
Texas Home Care Background Check Requirements 2026 — the four required checks (DPS Chapter 250, SEMARC EMR+NAR, OIG exclusion) and the August 2026 SEMARC transition

All information is current as of October 2026 under 26 TAC Chapter 558 as administered by HHSC. Verify current requirements at hhs.texas.gov before relying on this guide for compliance decisions. Regulatory standards are subject to change through HHSC policy letters and Texas Register amendments.