Texas HCSSA Personnel File Requirements: Home Health, Hospice and PAS Under 26 TAC 558 (2026)

Texas does not license home health agencies, hospices and personal care agencies separately. Anyone who provides home health, hospice, habilitation or personal assistance services for pay needs a home and community support services agency (HCSSA) license from the Health and Human Services Commission (HHSC) "for each place of business from which home health, hospice, habilitation, or personal assistance services are directed" (Texas Health and Safety Code (HSC) §142.002(a)). The license carries categories, and 26 TAC §558.13(b) recognizes six:

• licensed and certified home health services, the category a Medicare-certified agency holds;
• licensed and certified home health services with a home dialysis designation;
• licensed home health services;
• licensed home health services with a home dialysis designation;
• hospice services;
• personal assistance services (PAS).

Branch office licenses exist for the home health and PAS categories, and hospices use alternate delivery site licenses instead (HSC §§142.008(a), 142.0085). A license runs three years (HSC §142.006(b)).

The personnel rules are in 26 TAC chapter 558, which moved from 40 TAC chapter 97 in 2019 and was last rewritten effective April 25, 2021. HHSC readopted it unchanged after its four-year review in November 2025 (50 TexReg 7587). Most of chapter 558 applies to every category; Subchapter D adds rules for each category, and Subchapter H covers hospices. Criminal history and registry checks come from HSC chapters 250 and 253 and the registry rules in 26 TAC chapter 561. A Medicare-certified agency or hospice also meets the federal Conditions of Participation, which the home health and hospice personnel file audit checklist covers item by item.

On September 18, 2026, HHSC proposed amendments, new sections and repeals across chapter 558 (51 TexReg 6429, rule project 22R045). Comments close October 19, 2026, and the earliest possible adoption date is October 18, 2026. None of it was in effect when this guide was reviewed on October 16, 2026, and the guide describes the rules in force. The personnel changes HHSC proposed include:

• SEMARC, the multi-agency misconduct search, written into §558.247 for any person who may have direct contact with a client, licensed or not, including contractors and volunteers, with the Medication Aide Registry added to the annual searches;
• a written 72-hour emergency hire rule, and suspension of an employee while they appeal an HHSC finding of reportable conduct;
• a new §558.251 requiring training on abuse, neglect and exploitation (ANE) and two signed acknowledgments from every employee, contractor and volunteer "before an employee, volunteer, or contractor assumes job duties and at least annually thereafter," and reporting to HHSC "immediately but not later than one hour after suspecting or learning of the incident";
• virtual training, with clinical competencies "demonstrated and evaluated in person," and a "pseudo-person" allowed in aide competency evaluations;
• RN supervision of unlicensed staff in licensed home health, and volunteers allowed to serve as aides and attendants;
• personnel records for the administrator and alternate "regardless of ownership of the agency," with their training records in the file;
• deadlines to send accreditation documents (seven days) and to report a loss of accreditation (five days);
• a five-year retention period for personnel records, but only after an agency dissolves.

HHSC can adopt the proposal with changes. We will revise this guide when the adoption notice is published.

Section 558.245 requires written staffing policies that "govern all personnel used by the agency, including employees, volunteers, and contractors," and §558.246 sets out the record itself. For each employee and volunteer, the personnel record must include:

1. a signed job description and qualifications for each position accepted, or a signed statement that the person read them;
2. the application for employment or the volunteer agreement;
3. "verification of license, permits, references, job experience, and educational requirements, as conducted by the agency to verify qualifications for each position accepted";
4. performance evaluations and disciplinary actions;
5. for direct care staff with client contact, the signed statement that they "have read, understand, and will comply with all applicable agency policies" (§558.245(b)(10));
6. for unlicensed employees and volunteers with face-to-face client contact, printed results of the initial and annual Nurse Aide Registry and Employee Misconduct Registry searches, and proof they received written information about the registry.

Records may be electronic "if it meets the same requirements as a paper record," and "All information must be kept current" (§558.246(a)). They may be kept anywhere, but a record stored away from the survey site must reach the surveyor "within eight working hours after the request" (§§558.246(b), 558.507(c)). The staffing policies behind the record must also require an annual evaluation of every employee and volunteer, a job description and qualifications for every position, orientation and job-specific training, and a demonstration of competency for tasks "when competency cannot be determined through education, license, certification, or experience" (§558.245(b)).

Contractors are different. An agency "is not required to maintain a personnel record for independent contractors or staff who provide services under arrangement with another agency or organization." On request, though, it must show at the survey site within eight working hours that they meet its written job qualifications, along with registry and criminal history proof for unlicensed staff under arrangement (§558.289(e)).

What the rule leaves out. HHSC's FAQ says "Any additional requirements will be based on agency policy," and that §558.246 does not require a copy of the employee's driver's license. Chapter 558 sets no method for verifying a license and no duty to re-verify one at renewal, and it sets no retention period for personnel records.

HHSC's regulatory services report for fiscal year 2025 lists the ten state violations cited most often at home health agencies. Four are personnel-file items:

The most-cited violation, at 146, was failing to let a surveyor in within two hours or to have someone designated who could (§558.523(e)). That is a staffing item too: the administrator must designate, in writing, the employees who may admit a surveyor when the administrator and alternate are away (§558.243(b)(3)).

Chapter 250 makes an HCSSA a covered facility (HSC §250.001(3)(C)), and 26 TAC §558.247(a) puts the duty on the agency: it "must conduct a criminal history check authorized by, and in compliance with, Texas Health and Safety Code Chapter 250" for an unlicensed applicant or employee whose duties include face-to-face contact with a client. A volunteer with face-to-face contact is checked "before an unlicensed volunteer's first face-to-face contact with a client" (§558.247(b)(1)), and for unlicensed staff supplied by another agency or organization, the agency must ensure that organization runs the check before the person's first client contact (§558.289(d)). Licensed staff are exempt from chapter 250 at an HCSSA (HSC §250.003(a-1)), with one large exception: a hospice must check "all hospice employees and volunteers with direct client contact or access to client records," licensed or not (§558.855(a)).

The check. The agency may get the record directly from the Department of Public Safety (DPS) or pay a private agency to obtain it from DPS, using the person's name, race, sex, identifying numbers and date of birth (HSC §§250.002(b), 250.004(a)). Neither the statute nor chapter 558 mentions fingerprints, an FBI check or a national search, and DPS itself warns that a name search "will not provide a definitive match or no-match." No rule requires a periodic re-check; the statute leaves later checks to "other times as the facility or individual employer may determine appropriate" (HSC §250.004(a)).

Before the first client contact. "If a facility employs a person pending a criminal history check, the facility shall ensure that the person has no direct contact with a consumer until the facility obtains the person's criminal history record information and verifies the person's employability under Section 250.006" (HSC §250.003(a-2)), and direct contact means "any contact" (§250.001(2)). In an emergency, a person may be hired on a temporary basis only if the check is requested "within 72 hours of employment" (§250.003(b)).

Bars to employment. The offenses in HSC §250.006(a), among them criminal homicide, kidnapping, sexual assault, aggravated assault, injury to a child, elderly individual or disabled individual, robbery, arson, health care fraud and exploitation, bar employment with no stated end date, and the list reaches substantially similar offenses under other states' and federal law. The offenses in §250.006(b), among them Class A or felony assault, burglary, felony theft and misapplication of fiduciary property, bar a direct contact position "before the fifth anniversary of the date the person is convicted." A completed deferred adjudication with a dismissal and discharge is not a conviction (§250.006(d)). For any conviction that is not on the list, "the agency must document its review of the conviction and its determination of whether the conviction is a contraindication to employment" (§558.247(a)(2)), and an employee whose check shows a barring conviction must be discharged immediately (HSC §250.003(c)(2)).

The record. Section 558.246 does not list the criminal history report among the personnel record contents, and the report is confidential: it "may not be released or otherwise disclosed to any person or agency except on court order or with the written consent of the person being investigated" (HSC §250.007(c)). What the agency must be able to produce is documentation of compliance on HHSC's request (§558.247(c)) and its written review of any conviction that is not an automatic bar.

Three registry duties run side by side, and the annual search is the second most-cited home health violation in Texas.

Before hire, then every 12 months. Before hiring an unlicensed applicant, or before an unlicensed employee's first face-to-face contact with a client, the agency "must search the nurse aide registry (NAR) and the employee misconduct registry (EMR) using the HHSC website" and may not employ anyone listed as unemployable (26 TAC §558.247(a)(3)). It repeats both searches "at least every 12 months" (§558.247(a)(5)(B)). The same timing applies to volunteers, and the agency or the supplying organization does the same for unlicensed staff under arrangement (§§558.247(b), 558.289(c)). The statute requires the search before hire and then "annually," with a copy of the results kept (HSC §253.008(a), (c)).

SEMARC since 2026. The Search Engine for Multi-Agency Reportable Conduct (SEMARC), created by HSC chapter 810, now carries the Employee Misconduct Registry along with findings from the Department of Family and Protective Services, the Texas Education Agency and the Texas Juvenile Justice Department. Since July 23, 2026, the registry rule says an agency "must conduct a SEMARC check," "must also search the Nurse Aide Registry (NAR)," and must search both every year (26 TAC §561.3(a), (b), (e)). HHSC's provider letter makes SEMARC required for HCSSAs "beginning August 3, 2026," says "HHSC will not survey for compliance for SEMARC requirements until January 7, 2027," and reads the duty to cover contractors, volunteers and "licensed and unlicensed employees" (PL 2026-10, revised October 2, 2026). Staff hired before August 2026 can wait for their next annual check, and searches may run more often as long as no more than 365 days pass between them. The Nurse Aide Registry is not part of SEMARC and is still searched separately in TULIP (PL 2026-10). Chapter 558 itself still says EMR, still covers unlicensed staff only and still cites 40 TAC §93.3(c), a rule that no longer exists. Until it is amended, a file that shows a SEMARC search and a Nurse Aide Registry search for everyone with client access satisfies both texts.

Proof and notice. Keep a copy of every search (26 TAC §561.3(f)). HHSC's letter says SEMARC results must carry a time and date stamp, and since SEMARC does not print one, it says to screenshot the results page with the computer's date showing. Within five working days after hiring, give the employee written information that a person listed in SEMARC is not employable and that SEMARC and the EMR are governed by HSC chapters 810 and 253 (§561.3(d)), and keep proof that they received it (§558.246(a)(6)(B)).

Listed people. An agency may not hire or keep employing a person listed as unemployable in SEMARC or the Nurse Aide Registry (§561.3(c)), and must discharge an employee listed in either registry immediately (HSC §250.003(c)(1)). Since September 1, 2023, an agency must also suspend an employee whom HHSC finds engaged in reportable conduct while the employee appeals, without reinstatement during the appeal (HSC §253.0025).

Texas keeps its own exclusion list alongside the federal one. For Medicaid and other HHS program providers, it is grounds for sanctions to fail "to screen all employees and contractors for exclusions from the Medicaid or other HHS program on a monthly basis," to fail to document that they are not excluded, or to fail to inform the Texas Office of Inspector General immediately after identifying an excluded employee (1 TAC §371.1655(25)-(27)). The Texas Medicaid Provider Procedures Manual is direct: providers "must screen their employees and contractors every month" (TMPPM Vol. 1 §1.3.1, October 2026). An HCSSA with an HHSC community services contract, such as hospice, Primary Home Care or Community Attendant Services, must review both the federal and the Texas lists before hiring and "at least monthly" for each employee and subcontractor, and its records must show who was checked, who did the review, the date and the result (26 TAC §§52.107(f), 52.109(g)). The same contractors search the Comptroller's Debarred Vendor List before offering employment (§52.107(d)).

We found no Texas text that requires exclusion screening by an agency taking no Medicaid or other HHS program money. The federal payment bar still reaches anyone billing a federal health care program, and the OIG exclusion screening guide covers that side.

Administrator and alternate. The license holder must designate an administrator and, "in writing," an alternate who meets the same qualifications (26 TAC §558.243(a)), and HHSC allows only one of each per license (PL 2024-05). For home health and hospice, both must be a licensed physician, RN, licensed social worker, licensed therapist or licensed nursing home administrator with at least one year of management or supervisory experience in a health-related setting, or have a high school diploma or GED with at least two years of it, and a hospice administrator must also "be a hospice employee" (§558.244(a)(1)-(2)). A PAS-only agency's administrator needs a high school diploma or GED with a year of experience or training in caring for individuals with functional disabilities, or two years of full-time college study in a health-related field (§558.244(a)(3)). The agency must notify HHSC "no later than seven days after the date of a change" in administrator or alternate (§558.218(a)).

Administrator training. The administrator and alternate, and for home health and hospice the supervising nurse and alternate, complete HHSC's Presurvey Training before the license application (§558.13(a)). A first-time administrator or alternate then needs 24 clock hours of training: eight in the 12 months before designation and 16 more "before the end of the first 12 months after designation," covering the licensing standards, HSC chapters 142 and 250, client rights, ANE, infection control, emergency preparedness and related subjects (§558.259(b)-(d)). After that, both complete "12 clock hours of continuing education within each 12-month period" (§558.260(a); §558.259(h)). Presurvey Training counts toward neither (§§558.259(g), 558.260(d)). The training records must show the class, the content, the hours and dates, and the trainer (§§558.259(f), 558.260(c)), and HHSC accepts licenses, resumes, reference checks with verifiable dates, transcripts and training certificates as proof of an administrator's qualifications (PL 2024-05). Missed continuing education was the fifth most-cited home health violation in fiscal year 2025.

Supervising nurse. Licensed home health, licensed and certified home health, and hospice agencies must employ or contract with a supervising nurse and designate a similarly qualified alternate "in writing" (§558.243(c)(1)-(2)). Each must "be an RN licensed in Texas or in accordance with the Texas Board of Nursing rules for Nurse Licensure Compact (NLC)" and have "at least one year of experience as an RN within the last 36 months," and dialysis agencies require more (§558.244(c)). The supervising nurse must "always be available to agency personnel, in person or by telephone"; the rule sets no full-time or on-site hours, and a change of supervising nurse is not on the seven-day reporting list. Agencies that provide only therapy, medical social services or nutritional counseling are exempt (§558.243(c)(3)).

PAS supervisor and branches. A PAS-only agency needs a supervisor who is a licensed nurse or has completed two years of full-time college study, and a person with a high school diploma or GED may substitute one year of full-time supervisory employment in a health care setting for each required year of college (§558.404(g)(2)). Where an agency has branch offices, or a hospice has alternate delivery sites, the parent agency's administrator or supervising nurse, or an alternate, must make a documented on-site supervisory visit "at least monthly" (§§558.321(d)(1), 558.322(c)(1)).

Texas has no home health aide registry, certification or state exam; HHSC's presurvey training says so in those words. In an agency providing licensed home health services, an aide qualifies by any one of six routes (26 TAC §558.701(a)):

1. one year of full-time direct client care experience in a hospital or nursing facility;
2. one year of full-time direct client care experience in an agency setting within the last five years;
3. a training and competency evaluation program that meets §558.701;
4. a competency evaluation program that meets §558.701;
5. a letter from a nursing school's director of programs or dean stating that the person is a nursing student who has demonstrated competency in basic nursing skills; or
6. listing on the HHSC Nurse Aide Registry "with no finding against the aide relating to client abuse or neglect or misappropriation of client property."

A person qualifying by a program must have provided home health services within the previous 24 months (§558.701(b)). A training program runs at least 75 hours under an RN with two years of nursing experience, one of them in home health care, with at least 16 hours of clinical experience and at least 16 classroom hours before any clinical work. It covers 14 required subjects, among them "the rights of the elderly," and includes "an assessment that the student knows how to read and write English and carry out directions" (§558.701(d)-(e)). An RN performs the competency evaluation. An aide rated unsatisfactory in more than one area fails, and may not perform a failed task without direct RN or LVN supervision until retrained and re-evaluated (§558.701(f)). HHSC's FAQ says current rules "do not allow the use of pseudo-patients" in that evaluation.

What Texas does not set for licensed-only aides: a supervisory visit interval or annual in-service hours. Supervision follows the license category, with the appropriate licensed professional "available to supervise as needed" (§§558.701(c), 558.401(d)), and the Board of Nursing delegation rules apply to delegated tasks. The staffing policies still require orientation, job-specific training, a continuing training program and an annual performance evaluation (§558.245(b)). Unlicensed staff in licensed home health must be at least 18, or a high school graduate or enrolled in a vocational program if younger (§558.401(g)).

Medicare-certified agencies meet 42 CFR part 484 (§558.402(a)), so their aides need the federal training or competency route, at least 12 hours of in-service training in each 12-month period and the federal supervision and observation schedule (42 CFR 484.80). An agency that runs its own aide program must also meet the Texas content and evaluation rules in §558.701(d)-(f) (§558.402(b)-(c)), which add the English assessment and the rights of the elderly to the federal list, and Texas restates the federal 24-month lapse rule (§558.402(e)).

Subchapter H applies to every licensed hospice, Medicare-certified or not (26 TAC §558.801(a)). A hospice aide must complete a training and competency evaluation program or a competency evaluation program that meets §558.843; a licensed-only hospice has no Nurse Aide Registry route. Training totals at least 75 hours, with at least 16 hours of supervised practical training after at least 16 classroom hours, under an RN with two years of experience, one of them in home health or hospice care. A person who has not provided home health or hospice aide services for pay in the most recent 24 consecutive months must requalify, and an RN performs the competency evaluation (§558.843(a)-(d)).

Once working, a hospice aide needs "at least 12 hours of in-service training during each 12-month period," counted by calendar year or from the employment or contract anniversary, supervised by an RN and documented (§558.843(e)). An RN visits the client's home "at least every 14 days" to supervise aide services, and the aide need not be present; an RN also makes an annual on-site visit to observe each aide giving care, and a confirmed concern about the aide's skills triggers a new competency evaluation (§558.842(d)-(e)). Medicare-certified hospices also meet 42 CFR 418.76(b) and (f) (§558.843(g)).

A hospice homemaker completes the agency's hospice orientation and training or is a qualified hospice aide, and homemaker services "do not include providing personal care or any hands-on services" (§§558.844(c), 558.845(a)). Every hospice orients "all employees and contracted staff who have client and family contact" on the hospice philosophy and supportive palliative care, assesses the skills and competence of everyone furnishing care, volunteers included, and keeps "a written description of the in-service training provided during the previous 12 months" (§558.857). It also provides infection control education to employees, volunteers and contract staff (§558.853(d)).

Volunteers "must meet the same requirements and standards in this chapter that apply to agency employees performing the same activities," work in defined roles under a designated agency employee, and need a personnel record with a volunteer agreement (§§558.248(b), 558.246(a)). The federal volunteer rule, including its level-of-activity standard, applies only to hospices certified by CMS (§558.248(a)).

A PAS attendant must be at least 18, or under 18 and a high school graduate or enrolled in a vocational program, and must have "demonstrated competency, when competency cannot be determined through education and experience, to perform the tasks assigned by the supervisor" (26 TAC §558.404(c)). Chapter 558 sets no training hours for attendants. How often they are supervised is set by a written agency policy "with input from the client or family on the frequency of supervision" (§558.404(g)). Unlicensed staff who give tube feedings or medication through a permanently placed gastrostomy tube must first complete a training and competency program, with a 100 percent score on a written test, a skills checklist and a return demonstration documented in the employee's file, and the qualified trainers' own competency is "evaluated and documented annually" (§558.404(h)).

Medicaid adds three items. An HCSSA providing Primary Home Care, Community Attendant Services or Family Care under an HHSC contract follows 26 TAC chapter 277, which moved from 40 TAC chapter 47 on July 1, 2024. The supervisor orients each attendant "on or before the time the attendant begins to provide attendant services," on a single signed document kept in the file (§277.25(c)-(d)); in-person supervisory visits happen "at least annually" (§277.65(b)); and every staff person is trained on the acts, signs and prevention of abuse, neglect and exploitation "before a staff person assumes job duties and at least annually" (§277.101(a)(3)). Personal care services for children under Texas Health Steps require attendants to be 18 or older, with no exception (1 TAC §363.603(a)(1)).

Every HCSSA must have a written policy to comply with the Board of Nursing's delegation rules: 22 TAC chapter 225 for clients with stable and predictable conditions in independent living environments, which includes hospice clients at home, and chapter 224 for acute or unstable conditions (26 TAC §558.298). Before delegating a nursing task, the RN must have instructed the unlicensed person or verified their competency, and "The competency of the unlicensed person to whom the nursing task is delegated must be adequately documented" (22 TAC §225.9(a)(2), (c)). The RN sets the frequency of supervision with the client. Fixed intervals exist only for insulin, with three supervisory visits in the first 60 days (§225.12(5)), and for unstable clients at home, every 14 calendar days (§224.7(2)(B)).

A person may administer medication to an HCSSA client only with a license that allows it, a medication aide permit, or under the Board of Nursing's delegation rules or the memorandum of understanding between the state and the Board of Nursing (HSC §142.021), and a home health medication aide must hold a medication aide permit (26 TAC §557.128(a)).

Beyond the aide and attendant rules, Texas requires less recurring training than many agencies assume:

Two points belong in orientation. Since September 1, 2023, abuse, neglect or exploitation by HCSSA staff is reported to HHSC (Hum. Res. Code §48.051(b-1)), and HHSC says agencies "will no longer be required to make a report to DFPS," even though §558.249(c) still names DFPS. And accreditors add items of their own: ACHC's free personnel file checklist, for example, asks for TB screening and an annual competency assessment, which are accreditation standards rather than Texas licensing rules.

HHSC surveys without warning: "HHSC does not announce or give prior notice of a survey to an agency" (26 TAC §558.505). After the initial survey, which a new agency must request within six months of licensure (§558.521(a)), the rule says HHSC surveys "within 18 months after conducting an initial survey and at least every 36 months thereafter" (§558.501(a)(2)). The statute, amended in 2023, now says the 18-month survey "may" be conducted (HSC §142.009(j)). HHSC lists personnel files among the systems it reviews at every survey, with administrative records, complaints, quality assurance, policies and client records (PL 2024-19), and at an initial survey "all personnel records of agency employees" must be available when the surveyor arrives (§558.521(d)(4)).

Accreditation. "Except for the investigation of complaints," an agency is exempt from additional HHSC surveys while it "maintains accreditation status for the services for which the agency seeks exemption" from an accreditation organization with current HHSC approval: The Joint Commission, the Community Health Accreditation Partner (CHAP) or the Accreditation Commission for Health Care (ACHC) (26 TAC §558.503; HSC §142.009(h)). The exemption runs service by service. The agency still needs the license and fee (HSC §142.006(c)), must send its accreditation documentation within six months of its initial license and with each renewal, and must have it on hand at any survey (§§558.521(f), 558.17(e), 558.525(c)). HHSC still investigates complaints, with authority to inspect personnel records (HSC §142.009(c)(1)), and its letter on ACHC says an agency that loses its accreditation is "subject to immediate licensing survey activity and enforcement" (PL 2016-08). Accreditation also brings a second set of personnel standards, so an accredited agency's files have to meet both chapter 558 and the accreditor's manual.

Chapter 558 sets no retention period for the personnel records of an operating agency. The five-year rule is for client records after discharge (§558.301(b)(1)), and HHSC says it "does not determine the retention timeframe for criminal history results." Other laws set periods for particular documents:

• Form I-9: three years after hire or one year after termination, whichever is later (8 CFR 274a.2(b)(2)(i)(A)).
• Bloodborne pathogens training records: 3 years from the training date, and exposure medical records for the duration of employment plus 30 years (29 CFR 1910.1030(h)).
• Registry search results: kept in the agency's records (26 TAC §561.3(f); HSC §253.008(c)).
• Exclusion reviews by HHSC community services contractors: the records listed in 26 TAC §52.109(g).

Under the pending proposal, a closed agency would keep personnel records for five years after it dissolves (proposed §558.217(f)). Until a rule says more, keep each record for the longest period that applies to anything in it.

A practical audit of a Texas HCSSA's personnel files runs in five steps:

1. Build the list from the roster, not the file cabinet. Include employees, volunteers, independent contractors and staff under arrangement who worked in the period a surveyor will review, plus anyone who left. For each person, note whether they are licensed and whether their duties include face-to-face client contact, and for a hospice, access to client records; those facts decide the criminal history and registry duties.
2. Check the six §558.246 items for every employee and volunteer, then the items for the role: aide qualification route, hospice aide in-service hours, PAS supervision records, delegation documentation, administrator training.
3. Check dates against each other. The DPS result comes before the first client contact. Registry searches come before hire and again within 12 months of the last one. The written registry notice is dated within five working days of hire. The administrator's 12 hours fall within each 12-month period from designation. For Medicaid providers, exclusion checks run every month.
4. Read the gaps against the most-cited list. Annual registry searches, administrator continuing education, verification of license and references, and evaluations in the file account for four of HHSC's top ten home health citations.
5. Fix forward and date honestly. A missing record obtained today carries today's date, and a corrective note that names the gap reads better to a surveyor than a backdated document.

Repeat the audit at least once a year, and recheck chapter 558 when HHSC adopts the September 2026 proposal.