HHS OIG — Washington adult family home oversight; 17 of 20 homes failed health and safety standards; COVID inspection suspension unremediated up to 3 years
A November 2024 HHS Office of Inspector General audit (OEI-09-23-00370) of Washington’s adult family home oversight program found 17 of 20 homes inspected did not meet at least one health and safety standard, and 19 of 20 failed at least one administrative requirement — 214 total compliance violations. The OIG attributed compliance gaps in part to COVID-era inspection suspensions that were never fully remediated, leaving some homes uninspected for up to three years.
What happened
Adult family homes (AFHs) are small licensed long-term care settings — typically serving 2 to 6 residents in private residences — that provide personal care and supportive services to elderly individuals and adults with physical or developmental disabilities. In Washington State, AFH licensing and inspection oversight is administered by DSHS Home and Community Services (HCS, which the task brief references as HHA). Washington’s AFH program operates under federal Medicaid Home and Community-Based Services (HCBS) waiver rules, making it subject to both state licensing requirements and federal Medicaid compliance obligations.
The HHS Office of Inspector General conducted an audit of Washington’s AFH oversight program and published findings in November 2024 (report OEI-09-23-00370). The OIG examined 20 adult family homes and reviewed compliance with health and safety standards and administrative requirements applicable under federal waiver rules and state law.
Key findings:
- 17 of 20 homes failed to comply with at least one health and safety requirement.
- 19 of 20 homes failed to comply with at least one administrative requirement.
- 214 total instances of noncompliance identified across the 20 homes.
- Some homes had not been inspected for up to 3 years, due to inspection suspensions implemented during the COVID-19 pandemic that were never fully remediated.
- A number of homes may have overlooked the requirement for a written succession plan because the requirement became effective during the pandemic, when inspection and compliance education activities were reduced.
The OIG attributed the compliance gaps significantly to the pandemic-era inspection suspension and the failure to return to full inspection schedules — or conduct catch-up inspections for homes that were overdue — after COVID restrictions lifted.
OIG recommendations: The OIG recommended that CMS take corrective action to strengthen Washington’s oversight of adult family home compliance with federal health and safety and administrative requirements.
What the primary source says
The OIG report (OEI-09-23-00370, November 2024): “17 of the 20 family homes did not comply with one or more health and safety requirements. 19 of the 20 family homes did not comply with one or more administrative requirements.” The report noted: “The requirement to inspect family homes was suspended during the COVID-19 pandemic, and some homes had not been inspected for up to 3 years.”
Status
OIG report published November 2024. The report includes recommendations to CMS for corrective action to strengthen Washington’s oversight program. As of this record’s last update, no confirmed corrective action plan has been independently documented. DSHS has not publicly announced a specific remediation timeline for inspection backlog clearance.
Note on date_surfaced: The triage CSV (R2-021) lists the publication date as 2024-11-15; the OIG report page confirms a November 2024 publication date (specifically November 13, 2024 per the page metadata). This record uses 2024-11-13 as the date_surfaced. The task specification listed September 2025 as the approximate date — the actual publication is November 2024, predating that estimate by approximately one year.
Why it’s in the registry
This is a federal oversight agency reaching into Washington’s state-licensed long-term care infrastructure and finding state oversight inadequate. The finding is not that the homes failed inspection — it is that the inspection regime itself failed to catch violations because the state did not maintain its inspection schedule. The 214 compliance violations across 20 homes are the visible consequence of that structural inspection failure. Adult family home residents — typically elderly or disabled adults living in private residences with 2-6 other residents — have very limited ability to self-advocate or report violations. When the inspection regime lapses, they are without a meaningful accountability mechanism.
The federal-escalation pattern documented here — state oversight fails, federal auditors audit the state — is the same pattern documented in WA-2026-DOJ-CRIPA-WCCW (DOJ Civil Rights Division investigating WCCW) and WA-2024-DSHS-DDA-OMBUDS (DD Ombuds documenting structural failures in DDA oversight). In each case, Washington’s own oversight mechanisms failed to identify or correct the harm before external review exposed it.
Reform implication
Post-emergency remediation of inspection backlogs should be mandatory, time-bounded, and independently tracked. When DSHS suspends inspections during a public health emergency, the administrative obligation to resume and conduct catch-up inspections should be governed by a statutory timeline, not by agency discretion. An inspection backlog that persists for three-plus years after the pandemic-era suspension — affecting some of Washington’s most vulnerable residents — is not a resource limitation; it is an accountability failure. The remedy is statutory inspection-rate floors with mandatory escalation and public reporting when compliance falls below standard. See [reform: dsh_long_term_care_oversight], [reform: federal_oversight_response], and [reform: independent_inspector_general].
Reform implication
The HHS OIG adult family home audit is federal oversight reaching down into a state-licensed long-term care program and finding state oversight inadequate. The pattern — state regulatory failure prompts federal auditors to audit the state's oversight program directly — is the same federal- escalation dynamic that the DOJ CRIPA investigation of WCCW (WA-2026-DOJ- CRIPA-WCCW) represents for corrections. In both cases, Washington's own oversight infrastructure failed to identify or correct the harm before a federal agency stepped in. The proximate cause identified by OIG is the COVID-19 pandemic inspection suspension that was never fully remediated. Homes that went uninspected for up to three years during and after the pandemic were allowed to continue operating without the health and safety verification required under federal Medicaid waiver rules. The decision not to return to full inspection schedules after the pandemic — or to conduct catch-up inspections for homes that fell behind — was an administrative choice with predictable consequences: 214 compliance violations across 20 homes, 17 of which failed at least one health and safety standard. Adult family homes are among Washington's most vulnerable long-term care settings: typically small (2-6 residents), operated out of private residences, and serving individuals who may be elderly, physically disabled, or cognitively impaired. Residents are often unable to self-advocate or report violations. The inspection regime is the primary accountability mechanism. When that regime lapses — even for pandemic reasons — there is no substitute enforcement pathway. The reform argument is structural: post-emergency remediation of inspection backlogs should be mandatory, time-bounded, and tracked independently. DSHS Home and Community Services administering a self-directed catch-up inspection plan without independent verification is the same structure that produced the inspection lapse in the first place. An independent oversight function reporting to the Legislature, with statutory authority to track inspection compliance rates for licensed long-term care settings, would have identified the post-pandemic backlog and triggered mandatory catch-up before a federal OIG audit was required. See [reform: dsh_long_term_care_oversight], [reform: federal_oversight_response], and [reform: independent_inspector_general].
Sources
- Washington State's Oversight Could Better Ensure That Adult Family Homes Comply With Health and Safety and Administrative Requirements (OEI-09-23-00370)“17 of the 20 family homes did not comply with one or more health and safety requirements. 19 of the 20 family homes did not comply with one or more administrative requirements.”