State Associations Urge CMS to Forgo Potential National Hospice Enrollment Moratorium

Why It Matters

The outcome will determine whether Medicare beneficiaries retain timely access to end‑of‑life care while regulators curb fraud, especially in regions that currently lack adequate hospice capacity.

Key Takeaways

• State hospice groups lobby CMS against nationwide enrollment freeze
• They propose geographically targeted moratoria focused on fraud hotspots
• Fraud schemes have cost Medicare millions and involve license flipping
• NPHI initially suggested a national moratorium, prompting industry pushback
• Targeted oversight aims to protect access for underserved aging populations

Pulse Analysis

CMS faces a delicate balancing act as it evaluates a proposed national moratorium on new hospice enrollments. On one hand, Medicare has seen a surge in fraudulent billing, license flipping, and duplicate hospice operations that have siphoned millions of dollars. On the other, legitimate providers argue that a sweeping freeze would choke the growth of hospice services in communities already grappling with limited end‑of‑life care options. The debate underscores the broader challenge of safeguarding program integrity without compromising patient access.

Industry stakeholders, led by state hospice associations from Florida, North Carolina and South Carolina, are pushing back against a one‑size‑fits‑all solution. Their letter to CMS emphasizes a risk‑based strategy that isolates fraud hotspots—such as California, Arizona, Nevada and Texas—while allowing new, high‑quality hospices to launch in underserved markets. By targeting suspicious billing patterns, ownership structures, and rapid license turnovers, regulators could focus enforcement resources where they are most needed, preserving capacity for aging populations that rely on hospice for dignified care.

The conversation reflects a larger shift toward nuanced oversight in Medicare’s home health and hospice programs. Alternatives to a national moratorium include enhanced data analytics, region‑specific audits, and mandatory 24/7 service verification for new entrants. If CMS adopts a geographically tailored approach, it could mitigate fraud without stalling essential service expansion, setting a precedent for future policy responses across the health‑care continuum. Conversely, a blanket freeze could trigger access gaps, prompting backlash from providers and patient advocates alike.