HOME HEALTH DEPOSITION
PREP PACKET
Targeted, clinically grounded deposition questions for home‑health nurses, therapists, aides, administrators, and agency leadership.
This deposition prep packet provides structured question sets designed to uncover deviations from home‑health standards of care, expose communication failures, and clarify the responsibilities of each staff member involved in the patient’s care.
Use these questions to prepare for depositions of home‑health nurses, therapists, aides, administrators, and agency leadership.
HOME‑HEALTH NURSE DEPOSITION QUESTIONS
Role & Responsibilities
• Describe your responsibilities for this patient.
• How many patients were assigned to you?
• What is the typical caseload for home‑health nurses in your agency?
• What training have you received regarding home‑health assessments and escalation?
Medication Management
• How did you verify the medication list?
• Were there any discrepancies between the list and what was in the home?
• How did you monitor for side effects or missed doses?
• Were medications reassessed after changes?
Assessment & Monitoring
• What assessments were performed at admission?
• How often were visits required for this patient?
• Were any visits missed or shortened?
• Did you notice any changes in condition before the escalation event?
Communication
• When did you notify the physician of changes in condition?
• What information did you communicate?
• How did you update the caregiver?
• Were there any delays in communication?
Documentation
• Did you document assessments and interventions in real time?
• Are there any gaps or late entries?
• Is there documentation of caregiver education?
THERAPIST (PT/OT/ST) DEPOSITION QUESTIONS
Role & Responsibilities
• What was your involvement with this patient?
• How often were you scheduled to visit?
• Did you communicate concerns to nursing or the physician?
Assessment & Safety
• What functional assessments were performed?
• Did you identify any safety risks?
• Were recommendations communicated to the team?
Documentation
• Are there notes documenting progress or decline?
• Were any concerns escalated?
HOME‑HEALTH AIDE DEPOSITION QUESTIONS
Role & Responsibilities
• What care did you provide (bathing, ADLs, safety checks)?
• How often were you scheduled to visit?
Observations
• Did you notice any signs of pain, distress, or decline?
• Did you report these observations to the nurse?
Documentation
• Did you document your visits and observations?
• Are there any gaps?
ADMINISTRATOR / DIRECTOR OF NURSING QUESTIONS
Policies & Procedures
• What policies applied to this patient’s care?
• Were those policies followed?
• How is staff trained on home‑health standards
Staffing & Visit Compliance
• What were staffing levels during the relevant period?
• Were there any missed or shortened visits?
• How are missed visits escalated internally?
Incident Review
• Was an internal investigation conducted?
• Were any corrective actions implemented?
• Were there prior similar incidents?
COMMUNICATION & ESCALATION QUESTIONS
Communication Pathways
• How should nurses communicate changes in condition?
• What is the expected timeframe for provider notification?
• How are caregivers instructed to contact the agency?
Escalation
• When should nurses escalate to the physician?
• When should they escalate to 911?
• Were escalation protocols followed in this case?
Documentation
• Is there documentation of communication attempts?
• Are there any missing or contradictory entries?
THEMES TO ESTABLISH BREACH
Use these question sets to uncover:
• Missed or shortened visits
• Abnormal vitals not addressed
• Medication errors
• Poor communication with physicians
• Failure to escalate
• Unsafe home environment not addressed
• Documentation gaps or contradictions
• No caregiver education
• Failure to follow the plan of care
These themes help build a clear breach narrative.