On May 13th, CMS announced a six-month nationwide moratorium on new Medicare enrollments for both hospices and home health agencies, citing what Administrator Mehmet Oz described as “systemic and deeply troubling fraud” in the space. As a provider community, we knew that more enforcement was likely coming. While the steps CMS took here aren’t exactly what the community was hoping for, it’s still good to see regulators recognizing the seriousness of the situation.
While we’re glad steps are being taken to get the bad actors out, there are immediate implications for your teams in the community and in the intake department.
The specifics are hard to ignore and will make headlines in your community if they haven’t already: 773 hospices in Los Angeles alone with suspended payments, $70 million in funds frozen, a new proposed public hospice scoring system designed to expose patterns of suspect utilization. This is a highly-publicized, sustained enforcement posture that is going to keep generating headlines for at least the next two quarters.
Take Steps Now to Maintain Community Trust
For agencies operating with integrity, you should act now to educate your community on what this means. Compliance has always been table stakes, but for the next six months it is also a story your team must tell out loud with clarity and conviction. The referral source who reads the news in the morning and meets with your liaison in the afternoon will need context and details. The adult daughter who Googles “hospice” before her admission call will see the headlines. Silence is no longer neutral. If your team does not shape the narrative around your agency, the national coverage will fill in the blanks.
6 Talking points for your liaisons
4 Talking points for your intake team
What leadership’s next move should be
Downloadable PDF of talking points
Talking points for your liaisons
These are the six points your hospice liaison team should be carrying into every referral source conversation this week and for the duration of the moratorium.
1. Lead with continuity. “You may have seen the CMS announcement. The moratorium only applies to new agencies trying to enter Medicare. We’re an established provider, fully accredited, and operating exactly as we were last week. Your patients will see no disruption.”
2. Acknowledge the broader concern directly. “The fraud problem CMS is responding to is real, and frankly we’re glad they’re taking this seriously even if we don’t fully agree with this recent action. The activity in Los Angeles and a handful of other markets has been damaging to the entire community, including agencies like ours that are doing the work the right way.”
3. Offer specifics, not slogans. Be prepared to name at least three concrete proof points: years in operation, accreditation status, current CAHPS or HIS performance, and your compliance program. CMS specifically called out ownership changes as a vector bad actors use to evade detection, so a stable ownership story carries weight in this moment.
4. Position the moratorium as well-intended, not punitive. “What CMS is doing is trying to root out the truly fraudulent actors, even if a moratorium is overly-broad. These fraudsters have made every hospice conversation harder. Targeted fraud crackdowns will get them out and that’s good for your patients and good for referral partners who want confidence in their hospice.”
5. Never disparage a specific competitor. The temptation will be there. The risk is not worth it. Speak to category-level dynamics and your own performance and let the data and the regulators sort the rest.
6. Don’t allow it to be a barrier to care. Nobody calls hospice on a good day. Patients need us now. Work hard to educate referral sources on the critical role hospice plays in easing symptoms. Offer to be an ongoing resource if they have questions about what the moratorium means.
Talking points for your intake team
Intake conversations require a different register. Families are not parsing Medicare enrollment policy. They are asking, often without saying it explicitly, whether they can trust you with their loved one.
1. If a family raises the news, address it directly and without defensiveness. “I’m glad you asked. The news is about new agencies trying to enter Medicare, not about us. We’ve been serving families in this area for many years, and we’re fully compliant with everything CMS asks of us. Your loved one’s care will not be affected by any of this.”
2. Weave integrity into admission even when the family does not raise it. The phrasing should sound natural rather than rehearsed. Something like, “One of the reasons families choose us is that we’ve been doing this for a long time and we do it the right way. That matters more in hospice than almost anywhere else in healthcare.” Then move forward into the clinical conversation.
3. If asked directly whether you’re “one of the ones being investigated,” answer calmly and add context. A simple “no, we’re not, and here’s how you can verify that” tends to land better than a defensive explanation. Direct them to sources like Care Compare to highlight your quality scores, or to The Alliance’s CaringInfo website for resources to help them make an informed decision.
4. Translate compliance into care continuity in plain language. Families don’t care about enrollment regulations in the abstract. They care that their mother will get the visits she’s supposed to get, from the people she’s supposed to see, with the medications she actually needs. Make that connection explicit.
The leadership move this week
This moment rewards visible internal leadership. Get your liaisons, intake coordinators, and clinical managers aligned on the same language before the end of the week. Your director of nursing and the VP of business development need to be saying the same thing about the same news, because inconsistency between clinical and growth is where families lose trust fastest. Internal alignment is also the difference between highlighting your integrity and commitment to high-quality care, and being bunched in with bad actors.
The agencies that come out of the next six months stronger will not be the ones who waited for the news cycle to subside. They will be the ones who used the window to make their integrity legible to the referral sources and families who needed a reason to choose them. In this moment, compliance is not just an operational posture. It is a competitive position and a form of mission protection.
We’ve pulled the talking points above into a two-sided one-pager your team can carry into the field. Download it here, brief your team this week, and revisit it monthly through the duration of the moratorium.
Need a sounding board? Reach out to us anytime.
