Important for Hospices: Assess Your Enrollment & Affiliation Risk!
As CMS continues its aggressive efforts to combat fraud, waste, and abuse within the Medicare program, hospice providers are seeing a significant evolution in enforcement activity. Recent revocations suggest that CMS is no longer focusing solely on individual providers, but increasingly on the individuals who own, manage, or control those organizations. In a recent case, a hospice provider’s Medicare enrollment and billing privileges were revoked after failing to submit Medicare claims for a period exceeding six months.
While enrollment revocations for non-billing activity are not uncommon, the broader consequences that followed are drawing significant attention throughout the hospice industry. CMS subsequently revoked the Medicare enrollment and billing privileges of several additional hospice providers due to affiliations with the individuals identified in the original revocation action. These hospices had reportedly been actively serving Medicare beneficiaries for years and had ongoing operations. Nevertheless, CMS determined that the ownership and management affiliations posed an undue risk to the Medicare program under 42 CFR §424.535(a)(19).
This enforcement authority permits CMS to revoke a provider’s or supplier’s enrollment when it determines that an affiliation with an individual or entity subject to certain adverse actions poses an undue risk of fraud, waste, or abuse to the Medicare program.
Please use this tool to ensure you are asking the right questions to avoid any unexpected repercussions even due to affiliations!
