Every hospice license current, verified and in the file
Federal rules require hospice professionals to be licensed, certified or registered as their state requires, with qualifications kept current at all times. Personnel Ledger holds each license number, issuing state, expiration date and verification, and emails people before a license lapses.
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Built from the federal hospice personnel qualification rules, CMS survey reports and state licensing information. General information, not legal advice. Confirm your specifics with your state and your accreditor.
Licensed where the state requires it, and current at all times
Professionals who furnish services directly, under an individual contract or under arrangements must be licensed, certified or registered as their state requires.
42 CFR §418.114(a)The rule's own words: "all personnel qualifications must be kept current at all times." A license that expired before the renewal came through is a gap in the file.
42 CFR §418.114(a)Physicians, social workers, therapists, marriage and family therapists and mental health counselors each have their own qualification rules, on top of any state license.
42 CFR §418.114(b)Social workers need a master's in social work, or a bachelor's in social work or a related field supervised by an MSW, plus one year of social work experience in a health care setting. A BSW employed by the hospice before December 2, 2008 does not need MSW supervision (42 CFR §418.114(b)(3)).
Therapists and their assistants need the education path the rule names for their discipline, such as an accredited physical or occupational therapy program, as well as a state license wherever the state licenses the discipline (42 CFR §418.114(b)(4)-(8)). For the medical director and physicians, see hospice physician credentialing.
Fewer citations, but they recur
By our count of CMS survey reports, licensure and discipline qualification tags drew fewer citations than aide or background check findings, but each one appeared in both 2024 and 2025.
Source: our count of CMS QCOR hospice survey reports (Form CMS-2567), CY2025 standard surveys with at least one finding. Occupational therapy (L0789) drew 15 and physical therapy (L0791) 6, also all from one accreditor.
No verification on file
A hospice that could not produce an aide's HR file, with no verification or documentation of the person's credentials.
Outside the license
A licensed vocational nurse who pronounced a death, which the surveyor said California law does not allow, cited under the same licensure tag.
A BSW without supervision
A social worker with a bachelor's degree seeing patients without the MSW supervision the rule requires.
Credentials left to lapse
In an earlier federal review of hospice surveys, one hospice had 34 of 35 staff without updated credentials.
A license checked, not just copied
A common practice is to verify each license with the issuing state board, or through Nursys for nurses, at hire and after each renewal, and keep the dated result. No federal hospice rule spells that step out, but accreditors expect credentialing to be current, and a dated verification is what shows it.
| State | Nurse Licensure Compact |
|---|---|
| California | Not a member |
| Texas | Member since January 19, 2018 |
| Florida | Member since January 19, 2018 |
| Ohio | Member since January 1, 2023 |
| Pennsylvania | Fully implemented July 7, 2025 |
| Georgia | Member |
| Arizona | Member |
| Illinois | Not a member |
| New York | Not a member |
| Michigan | Not a member; a bill is pending |
An RN's license matters beyond their own file: the aide competency evaluations and in-service sessions they sign rely on it being current on those dates.
Every license, its verification and its history
License details
Record the license number, the issuing state and the expiration date for each license a person holds, and note a multistate license.
Verification beside it
Record when the license was verified, where and by whom, so the file shows it was checked.
Renewals keep history
A renewed license goes on top and the earlier one stays in the file.
By role
RN, LVN, social work and therapy licenses apply to the roles that hold them. A person with two roles carries both sets.
Reminders and digest
The license holder gets an email before it expires, and managers see every upcoming expiration in one weekly email.
Hospice license tracking, answered
What does "kept current at all times" mean for hospice licenses?
It is the wording of 42 CFR §418.114(a): all personnel qualifications must be kept current at all times. In practice a license should never be expired on a day the person works, so track the expiration date and renew ahead of it.
Do contracted therapists need their licenses on file?
Yes. The licensure rule reaches anyone who furnishes services directly, under an individual contract or under arrangements (42 CFR §418.114(a)). Keep their license number, issuing state and expiration date the same way as an employee's.
What qualifications does a hospice social worker need?
A master's in social work, or a bachelor's in social work or a related field supervised by an MSW, plus one year of social work experience in a health care setting (42 CFR §418.114(b)(3)). A BSW employed by the hospice before December 2, 2008 does not need MSW supervision.
Should we verify licenses with the state board?
It is common practice, and it is what makes a license in the file credible: verify with the state board, or through Nursys for nurses, at hire and after each renewal, and keep the dated result. No federal hospice rule names the step, but accreditors expect credentialing to be current.
Can we track multistate nursing licenses?
Yes. Record the issuing state, the expiration date and a note that it is a multistate license. Among the ten states we researched, California, Illinois, New York and Michigan were not Nurse Licensure Compact members as of October 2026.
What happens to the old record when a license is renewed?
Record the new expiration date and the new verification. The renewed license becomes the current record, and the earlier one stays in the person's history, so the file shows each license period.
This page is general information, not legal advice. Licensing rules come from your state boards, federal regulation and your accreditor, and they change. Confirm license status and compact membership with each state board.
Catch every license before it expires
Personnel Ledger keeps each license, its verification and its renewal history in the person's file. Start a free 45-day trial and add your licensed staff today.