Volume 26.02
The U.S. Centers for Medicare & Medicaid Services (“CMS”), as well as states are actively looking at efforts to strengthen program integrity across all Medicare and Medicaid programs, including hospice. Hospice providers should be preparing for potential integrity expansion to include:
- Further expansion of claim review and audit processes,
- Expanded enrollment moratoriums for newly enrolled hospices,
- Further expansion of the provisional period of enhanced oversight (“PPEO”) (see below),
- Strengthened enrollment controls, which could be quite extensive,
- Increased site visits,
- Potential capitalization requirements for new and existing providers,
- Increased identification of hospices with persistent problems and increased oversight of these hospices,
- Establishment of targeted off-cycle Medicare enrollment revalidations,
- Increased oversight of Medicare Administrative Contractors (“MACs”) and their performance, and more.
In January 2026, CMS extended PPEO to hospices in Georgia and Ohio. PPEO, already being applied in California, Arizona, Nevada, and Texas, is for new hospices. New hospices are defined as:
- Newly enrolling in the Medicare program,
- Submitting a change of ownership as described in 42 CFR 489.18,
- Undergoing a 100% ownership change that doesn’t fall under 42 CFR 489.18, or
- Reactivating Medicare enrollment after being in deactivated status.
PPEO can include a period of as little as thirty (30) days or for a period of up-to one (1) year.
Hospices in these states are also potentially subject to expanded prepayment review, which applies to existing hospices.
Additional information is available here and here.
Compliance efforts, current and potential, will be discussed at the upcoming CHAPCA Hospice Financial Administration Program scheduled for March 24-25, 2026. Program information and registration is available here. The Health Group, LLC’s clients can secure discounted registration by using the discount code HealthGroup at the end of the registration.
CHAPCA PROGRAM OFFERS EXPANDED HOSPICE CAP AND COST REPORTING PROGRAMS
The upcoming CHAPCA Hospice Financial Administration Program will include the most comprehensive programs available on Hospice CAP and Hospice Cost Reporting, and you can find details here.