Sep 17, 2026 · 18 min · 8 segments
A short-term home health and moratorium was a necessary action because of rampant fraud in the hospice sector, said Tom Koutsoumpas, founder and CEO of the National Partnership for Healthcare and…
Tom KoutsoumpasGuest
Liza BergerHost
In the most recent letter, as I mentioned, you did ask for a more targeted approach.
You said the moratorium, quote, does not distinguish between those actors and the mission driven community based nonprofits that make up the backbone of hospice care in this country.
I think that as we look at this for the long haul, we've got to create an approach that allows for sustainability.
It's designed to sort of look at the most egregious activities and try to contain them to address them.
But what are you going to do for the long haul? You could certainly extend the moratorium for another six months or whatever timeframe CMS felt like they might need.
For the ongoing activity, you need to provide some kind of approach that allows you to do that for years, not just months, to make sure that these fraud and abuse issues are addressed on an ongoing basis.
So what we've done is we've really looked at how could CMS approach this in a way that allowed for that sustainability? And our thought was a really more targeted approach where you look at different factors that might be red flags.
Are you discharging an extraordinary number of people alive, for instance? Are you enrolling people and then discharging them? there are gaming approaches that some programs and people take advantage of.
Looking at the statistics, looking at approaches that are raising these red flags is a way to target and then go after those programs with a real severity.
We are really concerned that, yes, you can go in and create a moratorium and go after the most egregious programs, But what happens six months down the road after that, after it's over? How are you going to address this? And how do you focus on the programs that are most egregious?
In the most recent letter, as I mentioned, you did ask for a more targeted approach.
You said the moratorium, quote, does not distinguish between those actors and the mission driven community based nonprofits that make up the backbone of hospice care in this country.
I think that as we look at this for the long haul, we've got to create an approach that allows for sustainability.
It's designed to sort of look at the most egregious activities and try to contain them to address them.
But what are you going to do for the long haul? You could certainly extend the moratorium for another six months or whatever timeframe CMS felt like they might need.
For the ongoing activity, you need to provide some kind of approach that allows you to do that for years, not just months, to make sure that these fraud and abuse issues are addressed on an ongoing basis.
So what we've done is we've really looked at how could CMS approach this in a way that allowed for that sustainability? And our thought was a really more targeted approach where you look at different factors that might be red flags.
Are you discharging an extraordinary number of people alive, for instance? Are you enrolling people and then discharging them? there are gaming approaches that some programs and people take advantage of.
Looking at the statistics, looking at approaches that are raising these red flags is a way to target and then go after those programs with a real severity.
We are really concerned that, yes, you can go in and create a moratorium and go after the most egregious programs, But what happens six months down the road after that, after it's over? How are you going to address this? And how do you focus on the programs that are most egregious?
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