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Volume 26.09

On May 13, 2026, CMS announced a six-month moratorium on hospice and home health agencies to protect patients, restoring integrity and safeguarding taxpayer dollars.

The Health Group, LLC, has always believed that a moratorium placed on hospice and home health agencies is an inappropriate action that does not address the real fraud and abuse problem, but instead impacts quality providers that would otherwise expand activities and, of course, could impact patient access to care.  Individuals and entities entering the hospice and home health industry were inadequately screened and monitored by those responsible for overseeing the enrollment process, (CMS, states, and surveying agencies), providers failing to update enrollment timely, and a lack of appropriate targeted claims reviews.

If a moratorium were of value, it would be restricted to a set period during which CMS would be required to enhance the enrollment and oversight process.  As it currently exists, we expect the moratorium to be extended beyond the current six-month period, because appropriate actions will not be taken by CMS in this timeframe to address the issues long term.

Those who have actively advocated for a moratorium in the past, even in selected geographical areas, failed to fully consider the implications on quality providers and how CMS would respond to such an “endorsement” of this type of policy.  Even a moratorium in such selected areas is not a long-term solution.  Strengthening enrollment oversight, both initial and ongoing, is far more appropriate when applied in conjunction with targeted claims reviews.

At the time of establishing the moratorium, CMS also indicated that there would be other activities including nationwide hospice site visits to verify operations and identify suspicious activity.

HOSPICE PAYMENT SUSPENSIONS

Hundreds of hospices, primarily in California, have been placed on payment suspensions by the Medicare program based on global criteria that CMS has developed.  These criteria, based on information available, are, principally, based on live discharge rates.  While we support identifying and targeting inappropriate and potentially fraudulent providers, we strongly support due diligence before any suspension and an appropriate rebuttal process for the providers allowing for any inappropriate suspension of payments.

Many legitimate providers appear to be included in the payment suspensions.  Supposedly, the providers included in the suspension were given fifteen (15) days to submit a rebuttal to the payment suspension.  Many hospices have submitted rebuttals; however, any response to those rebuttals appears to be non-existent or inadequate at best.

Based on early indicators, many legitimate providers may be forced to shut down in addition to those that otherwise should be shut down.  The Health Group, LLC supports efforts to reduce fraud and abuse but also expects the government to allow quality providers to continue services to patients.  The assumption that everyone is guilty of fraud and abuse without appropriate evidence and/or an appropriate and timely rebuttal process is totally inappropriate. We applaud “Hospice News” for reporting on this issue here.

REGISTRATIONS NOW BEING ACCEPTED FOR LAS VEGAS PROGRAM

The 2026 “Hospice Financial & Compliance Management Conference” is now available to registration.  The two-day program is being held at Paris Las Vegas on October 1-2, 2026.

As always, this program offers the most extensive hospice financial coverage available.  The integration of finance and compliance is critical to survival and success of any hospice.  This year compliance and the associated financial risks are critical.  Initial information and registration information is available here.  Discounted room rates are available here or by calling (877) 603-4389.  Make certain to inform Paris Las Vegas that you are attending The Health Group program.  See you in Las Vegas.