2 min read
The hospice moratorium may eventually end—but the era of heightened scrutiny it represents is likely just beginning.
In Part Two of The Hospice Moratorium: What CMS Is Really Signaling About the Future, Chris Comeaux and Cordt Kassner continue their conversation with Dr. Jennifer Kennedy, Vice President for Quality, Standards and Compliance at CHAP, to examine what hospice could look like after the moratorium is lifted. Jennifer predicts that new providers and changes of ownership will face a fundamentally different environment—one shaped by more rigorous enrollment screening, greater scrutiny, and an expanding use of data to identify potential risk.
For hospice leaders, the message is clear: compliance and quality can no longer operate as separate priorities; they must be embedded together in organizational culture. The conversation also tackles one of the industry's most important challenges: How can CMS aggressively target fraud and abuse without creating unnecessary burdens for legitimate, high-quality providers? Jennifer argues that data should be the starting point—but not the entire story.
Chris and Cordt explore whether AI, algorithms, and more sophisticated analytics could help regulators distinguish bad actors from organizations genuinely committed to serving patients and communities. Ultimately, the discussion returns to the heart of hospice: even in an increasingly regulated environment, leaders must preserve compassionate, patient-centered care and ensure that what matters to the patient remains at the center of every decision.
5 Key Takeaways
- The end of the moratorium won't mean a return to business as usual. Jennifer anticipates greater scrutiny of CMS 855 enrollment applications and changes of ownership, potentially creating a very different entry environment for future hospice providers.
- Compliance and quality must become one organizational culture. A strong compliance program, ongoing risk assessment, corrective action, staff accountability, and close attention to CMS and federal policy signals will be increasingly important.
- Hospices should budget for audits as a cost of doing business. Jennifer expects audits to become a more routine operational reality and specifically points to SSVI as another potential avenue for increased scrutiny.
- Better data and AI could make regulation more precise. The panel explores a future in which sophisticated analytics help CMS focus resources on waste, fraud, and abuse rather than sweeping legitimate providers into the same regulatory net.
- Compliance cannot come at the expense of compassion. Hospice organizations need the infrastructure to produce clean claims, accurate cost reports, and strong compliance performance while ensuring frontline teams understand the why behind the requirements and continue delivering compassionate care.
The question isn't simply when the hospice moratorium will end—it's whether your organization is prepared for what comes next.
Listen to Part Two to hear what Dr. Jennifer Kennedy, Chris Comeaux, and Cordt Kassner believe hospice leaders should be doing now to prepare for greater scrutiny, more sophisticated oversight, and a future where quality, compliance, data, and compassion must work together.
Listen, share this conversation with your leadership and compliance teams, and subscribe to TCNtalks and Anatomy of Leadership so you don't miss the conversations shaping the future of hospice.
*** 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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Our Special Guest
Dr. Jennifer Kennedy
Vice President, Quality, Compliance and Standards with CHAP
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CMS Hospice & Home Health Moratorium:
What CHAP Knows So Far
Co-Host
Cordt Kassner
PhD, Publisher of Hospice & Palliative Care Today
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Hospice and Palliative Care Today
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Our Host
Chris Comeaux
MLAS, CPA
President / CEO of Teleios
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