Increased Focus on Hospice Enforcement
Hospice enforcement continues to intensify as regulators focus on program integrity risks associated with end-of-life care, billing practices, and inappropriate admissions. Federal and state agencies have identified hospice as a sustained priority area, particularly as the Medicare Hospice Benefit expands and utilization patterns raise concerns about fraud, waste, and abuse. Federal hospice enforcement has shifted into a high-intensity, prevention-first model. This includes blocking entry (e.g., enrollment moratoria and enhanced screening), identifying outliers early (through scoring and analytics), and stopping payments more quickly (prepayment review and site visits).
A key recent development is the Center for Medicare & Medicaid Services (CMS) implementation of a six-month nationwide Medicare enrollment moratorium on new hospice and home health providers, effective May 13, 2026. CMS describes this action as part of a broader, “data-driven fraud prevention strategy” targeting hospice program integrity risks. The moratorium blocks new hospice Medicare enrollments and restricts changes in majority ownership for new applicants, with the goal of preventing the rapid entry of fraudulent providers and “shell hospices.”
Additional CMS initiatives include the following:
- Deployment of a public hospice risk indicator scoring system that flags unusual utilization patterns, quality of care concerns, and compliance anomalies.
- Increased enforcement field activity, including unannounced hospice site visits nationwide, revocation and deactivation of noncompliant providers, and heightened screening of newly enrolling hospices in high-risk states (e.g., AZ, CA, NV, TX, GA, OH). These actions reflect a shift toward front-end prevention rather than post-payment recovery.
- Expansion of targeted pre-enrollment scrutiny for new and reactivated hospices, and ownership changes by requiring proper documentation and review before billing Medicare.
- Broadened prepayment claims reviews that apply to existing hospice providers in high-risk areas, increased claims review before payment is released, particularly targeting billing anomalies in length of stay patterns, diagnosis eligibility, and service intensity.
Increased coordinated federal enforcement efforts, including a national anti-fraud initiative and increased collaboration with law enforcement for false eligibility certification cases, kickback and referral schemes, and concealed ownership structures.
Interested in learning how the current regulatory environment might affect your organization? Contact Richard Kusserow at [email protected] to discuss support for your program.
