The hospice moratorium isn’t simply a temporary pause—it may be one of the clearest signals yet that Centers for Medicare & Medicaid Services (CMS) is fundamentally changing how it oversees the hospice industry.

In Part One of this timely conversation, host Chris Comeaux and co-host Cordt Kassner,  sit down with Dr. Jennifer Kennedy, Vice President for Quality, Standards and Compliance at CHAP, to unpack what the CMS hospice moratorium means, why it was implemented, and what hospice leaders should be watching next.  Jennifer explains how escalating concerns around fraud and abuse, rapid market expansion, transactional hospice models, accreditation oversight, and Medicare enrollment have created an unprecedented regulatory environment.  She also shares why she believes the moratorium could be extended as CMS continues strengthening enrollment screening and program-integrity efforts.

But increased scrutiny creates another challenge: How does CMS aggressively remove bad actors without trapping good providers in the same regulatory net?  The conversation explores the unintended consequences for legitimate hospices—including organizations seeking to expand into rural and underserved communities—and why the future of hospice will require stronger compliance, demonstrable quality, and greater accountability.  Jennifer's message is clear: even when the moratorium ends, heightened oversight will not.

5 Key Takeaways

• The moratorium is about much more than pausing new hospice enrollment.  CMS is using the enrollment entry point as part of a broader response to fraud and abuse across hospice, home health, and durable medical equipment (DME).
• Fraud and rapid market expansion are reshaping hospice oversight.  Jennifer points to extraordinary hospice growth in markets such as Los Angeles County and raises concerns about models built around obtaining licenses and Medicare certification and then selling the organization rather than building a high-quality care provider.
• The moratorium could be extended.  Jennifer believes six months may not give CMS enough time to address the depth of fraud, refine enrollment provisions, investigate complex financial activity, and strengthen screening—including the use of AI tools.
• Accreditors and regulators are part of the accountability equation.  The discussion examines whether state licensing and accreditation systems provided sufficient safeguards during periods of rapid hospice expansion and how CHAP has increased its own due diligence.
• Good hospices can get caught in a broad regulatory net.  Legitimate organizations—including those attempting to expand access in rural communities—may face unintended consequences.  The challenge for CMS is developing enough precision to target fraud while protecting providers delivering quality end-of-life care.

The moratorium may eventually end—but the era of heightened hospice oversight is just beginning.  Listen to Part One to understand what CMS may really be signaling, what it means for responsible hospice providers, and why leaders who make quality and compliance part of their organizational strategy—not simply a regulatory requirement—will be better positioned for what comes next.

And don’t miss Part Two, coming this Friday, as the conversation continues with what hospice leaders should be thinking about as the regulatory landscape evolves.

*** Referenced In Episode - Podcast with Kim Brandt

CMS Leader Explains Hospice Fraud, Medicare Risks, and the Future of Healthcare | Part One

CMS Leader Explains Hospice Fraud, Medicare Risks, and the Future of Healthcare | Part Two

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