How the 4 Largest Hospice Industry Groups Work Together to Support Program Integrity

The four largest hospice industry organizations have been working to present a united front to address widespread program integrity issues.

As those problems proliferate, the National Hospice and Palliative Care Organization (NHPCO), the National Association for Home Care and Hospice (NAHC), LeadingAge and the National Partnership for Healthcare and Hospice Innovation (NPHI) have been speaking out not only individually, but collectively. 

Though these groups have always collaborated, the gravity of the program integrity concerns require a more unified approach.


“There is definitely a concerted effort to work more closely together to address fraud, waste and abuse concerns that all well-meaning providers, regardless of tax status, can support,” Matthew Wilkinson, communications manager at NPHI, told Hospice News. “In the end, the fact is that progress always comes quickest when you have unanimity among stakeholders, which is what we’ve tried to pursue with regard to ongoing program integrity challenges.”

Each of the four organizations acknowledged the stepped up collaboration; each also asserted its independence and its individual priorities and initiatives.

Among the key issues that organizations seek to resolve involves a rash of new providers that have emerged so far in four states: California, Arizona, Texas and Nevada.


A large contingent of these companies were established with the purpose of selling the license at a profit, with little concern for patient care. In some instances, multiple hospices have been operating out of the same address without a corresponding increase in the population of eligible patients.

Many of these hospices were also setting up shop, providing substandard care to a few patients and then selling off the license before regulators caught wind of it. This prompted the U.S. Centers for Medicare & Medicaid Services (CMS) to propose a rule that would prohibit hospices from selling licenses or transitioning ownership for at least 36 months following initial Medicare certification.

Coming together to combat fraud

Beginning in 2022, NHPCO, NAHC, NPHI and LeadingAge began issuing a series of joint statements calling attention to the problem and proposing solutions.

“NAHC has long been a proponent of a unified voice in home care and hospice. One way to achieve that unity is through strong collaboration with other organizations,” Tom Threlkeld, director of communications, for NAHC told Hospice News in an email. “In recent times, the need and opportunities for that collaboration has increased and NAHC will continue to form collaborative relationships whenever we can.”

Last November, the organizations penned a joint letter to CMS in November urging for increased oversight to help curb fraud.

In January, they returned with a Hospice Program Integrity plan listing 34 recommendations that center around five key areas.

These areas include stronger oversight of hospice Medicare enrollment and billing practices, developing Medicare certification “red flag” criteria, expanding surveyors’ ability to confirm all four levels of hospice care, and adding education and experience qualifications in the Conditions of Participation (CoPs) for hospice administrators and patient care managers.

The four groups also called for a national moratorium on hospice licensing until regulators devise better methods of swiftly identifying fraudulent actors.

In addition to the fraud issue, they have spoken out individually and collectively on CMS’ methodologies for calculating reimbursement rates and claim coding for telehealth and chaplain services, as well as the design of the agency’s forthcoming Special Focus Program.

Awareness grows among policymakers

Another impetus for collaboration is growing awareness of hospice among lawmakers, which provides an opportunity to advocate for greater change, according to Mollie Gurian, vice president, home-based and home-and-community-based policy for LeadingAge.

“A lot of advocacy efforts, both at the state and federal level, are achieved through collaboration. What you are observing with LeadingAge, NHPCO, NAHC and NPHI is not new,” Gurian told Hospice News in an email “However, the partnership, if you will, has intensified as interest in hospice among various stakeholders and policymakers is growing. There’s an opportunity now to improve the benefit and beneficiaries’ experience. We all want to be involved. At the same time, we are also working hard to address LeadingAge members’ concerns, which we presented to Congress in late January 2023.”

Some of these organizations also collaborate in other ways. For example, NPHI, NAHC and NHPCO are each members of the National Coalition for Hospice and Palliative Care, a collaborative of more than a dozen advocacy groups.

NAHC and NHPCO earlier this year worked with NORC at the University of Chicago to publish a joint report showing that longer hospice stays reduce health care costs in the last year of life by as much as 11%.

Hospice care, all told, saves Medicare approximately $3.5 billion for patients in their last year of life, a 3.1% reduction, the report indicated. However, those with stays of six months or more yielded the highest percentage of savings.

“NAHC and NHPCO worked on the research study with NORC and yielded really valuable information about the savings to Medicare and the quality of care people are experiencing,” NHPCO COO and interim CEO Ben Marcantonio told Hospice News. “That influenced the messaging on [Capitol Hill]. We can go to our representatives in Washington and to the administration with a very unified message. So collaboration builds on collaboration because of the trust that is built and the synergy and the outcomes that are positive for the field and the community.”

NAHC and NHPCO explore possible affiliation

The relationship between NAHC and NHPCO may deepen going forward, as the two organizations have been in discussions of a potential affiliation.

In August, their respective boards signed a non-binding letter of intent to pursue a possible combination. If realized, NAHC and NHPCO would merge into a new, as-of-yet named entity.

“We’ve signed a letter of intent, and with that has moved us into a process of working in specific workgroups on key areas of what we do, around regulatory and policy, around advocacy, around education and quality programs,” Marcantonio said. “We’re working with these workgroups with leadership from our members, and seeing what those areas would look like if we come together in a way that is more of a combined and affiliated organization. That’s what will lead us to the next decision point in the months ahead.”

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