Four national hospice organizations have called on CMS and Congress to strengthen hospice program integrity through key legislative and regulatory changes.
The organizations, LeadingAge, the National Association for Home Care & Hospice (NAHC), the National Hospice and Palliative Care Organization (NHPCO), and the National Partnership for Healthcare and Hospice Innovation (NPHI), presented the proposed changes on Jan. 19, 2023.
The 34 recommendations are grouped into 11 core issue areas, according to a news release. The organizations noted five key points:
  • Limit enrollment of new providers with a targeted moratorium on new hospices: Use existing CMS moratorium authority to limit enrollment of new hospice providers in counties with troubling rates of explosive licensure and Medicare certification growth.
  • Enforce against non-operational hospices by revoking Medicare enrollment and increasing site visits: Investigate Medicare provider numbers that show aberrant gaps in Medicare billing. Revoking enrollment of non-operational hospices prevents them from being sold to inexperienced providers for a profit.
  • Develop hospice “red flag” criteria: Identify Medicare certification application “triggers” related to specific areas of concern that would prompt CMS to investigate an applicant before certification could be approved. Red flags should include:
    1. Co-location of multiple hospices at single address
    2. A single hospice administrator overseeing multiple hospices
    3. A patient care manager or other hospice leadership staff serving multiple hospices
    4. A hospice company that appears to be hidden behind a shell company
  • Require surveyors to confirm ability of hospices to provide all four levels of care:  Surveyors must ensure hospices have the ability to provide all four levels of care, including General Inpatient Care (GIP) and respite contracts, as well as provision for continuous home care (CHC) and afterhours care.
  • Add hospice administrator and patient care manager qualifications to Medicare hospice Conditions of Participation (CoPs): Add education and/or qualifications to the hospice CoPs for these key personnel, including minimum years of experience or a combination of education and experience.
“NAHC believes strongly that improved hospice program integrity will benefit patients, families, providers, and the Medicare program, and that it is an essential element in ensuring quality of care. Historically NAHC has strongly supported meaningful solutions to problems as they have arisen within hospice and other programs. The series of recommendations that we are putting forth in conjunction with other national hospice organizations clearly communicate our continued commitment to designing and supporting effective regulations, processes, and operational standards in hospice. We look forward to working with Congress and the Administration to move these recommendations forward,” stated NAHC President Bill Dombi.
The full list of recommendations is available at