(304) 241-1261 contact@healthgroup.com

Volume 23.17

Yesterday the Centers for Medicare and Medicaid Services (“CMS”) reported that nearly 400 hospices are being considered for potential administrative action.  This is the result of site visits to numerous hospices.  The site visits are the result of suspected non-operational hospice sites and what CMS refers to as “churn and burn” schemes.

The “churn and burn” scheme is when a new hospice opens and starts billing.  Once the hospice is audited or reaches the Hospice CAP, the hospice shuts down, fails to repay the debt to the Medicare program, and then acquires another hospice provider and transfers the patients to the newly acquired hospice and starts billing again.

The CMS report comes almost immediately after the initiation of numerous hospice integrity measures including implementing a period of provisional oversight in California, Nevada, Texas, and Arizona.  Proposed rules would enable CMS to apply the Period of Provision Oversight to hospices in other states and based on CMS determined criteria.

CMS is also initiating a project to review hospice claims following an individual’s first 90 days of hospice care.  This pilot project will not be limited to hospices in Arizona, Nevada, California, and Texas.  Some of the other initiatives proposed and finalized include:

  • Limiting the transfer of hospice provider agreements and Medicare billing privileges of a new hospice for 36 months and for 36 months following the transfer of a majority direct ownership interest (certain exceptions apply).
  • Clarification of managing employees for hospices.
  • Implementation of a “Special Focus Program” to increase oversight of poor performing hospices.
  • Heightened review of owners and managing employees, including their history with the Medicare program.
  • Enforcement of reporting related organizations and certain transactions.
  • Reporting certain misdemeanors and other circumstances as adverse legal actions as part of the Medicare enrollment and enrollment update process.
  • Increased scrutiny and screening of physicians certifying and serving Medicare hospice patients.

More information is available here.

CMS initiatives and the financial implications of such initiatives will be included in the upcoming 2023 Hospice Financial Management & Administration Conference offered by The Health Group, LLC.


The Health Group, LLC’s 2023 Hospice Financial Management and Administration Conference is rapidly filling up (attendance limited).  The program will be held at the beautiful Lago Mar Beach Resort, Fort Lauderdale, Florida on November 9-10, 2023.  Program information, including registration information, is available here.  The program provides for a special session on the financial implications of the many hospice integrity initiatives, both implemented and proposed.  The final Home Health and Physician Payment Rules are expected to be finalized before the conference.  These include many provisions impacting hospices and hospice financial management.

We are encouraging anyone who expects to attend to make room reservations at their earliest opportunity.  Many individuals planning on attending the program have already reserved their rooms.  The Lago Mar Beach Resort will sell out for the days of our conference.  Special rates have been secured with the Lago Mar Beach Resort & Club; however, to secure these rates, call (855) 829-2923 and inform the hotel that you are attending “The Health Group, LLC Hospice Financial Administration Conference” or online at www.lagomar.com.

When making reservations online, go to reservations, click on group code, and enter 2311THEHEA.  Select the dates you will be staying, even if the dates are indicated as not available, select them and your room type.  All attendees are being offered Executive One Bedroom Suites at $235/night.  Resort fees have been waived for our attendees.  If you have a problem, please call the hotel.  The hotel is making the $235/night available for two (2) days prior and two (2) days after the program dates.