Approved by the Executive Committee on April 17, 2026
The AAHPM Executive Committee of the Board of Directors, in close coordination with Academy staff and trusted stakeholder partners, has been actively monitoring and discussing recent events and actions, including those by the U.S. Department of Justice (DOJ), Department of Health and Human Services (HHS), as well as Congressional hearings related to hospice fraud.
The mission of the American Academy of Hospice and Palliative Medicine is to advance the field of hospice and palliative medicine, and our vision is that all patients, families, and caregivers who need care have access to high quality hospice and palliative services. In alignment with this mission and vision, the Academy offers the following statement:
The top priority of American Academy of Hospice and Palliative Medicine (AAHPM) is the well-being of patients and their caregivers, who deserve access to high- quality and ethical care. The hospice benefit was created more than 40 years ago as a compassionate promise to Americans supported by Medicare at the end of their lives: that people impacted by a terminal illness can receive high quality, whole-person care that honors their goals and values, alleviates suffering, and brings meaning to their most vulnerable season of life. We reaffirm our unwavering dedication to serving those in need of excellent hospice care and to supporting the physicians and members of the interdisciplinary team who deliver this care every day. As people who both deliver this care and have personally witnessed its impact on our own family members and friends, we recognize the unmatched value hospice care brings. That experience strengthens our resolute commitment to equitable access to high-quality hospice care.
Criminal actors using fraudulent hospices to obtain payments without providing appropriate care are despicable. These scams harm patients, misdirect limited funds, and undermine public trust. At the same time, imprecise enforcement actions can inadvertently penalize legitimate, mission driven hospices, thereby limiting access to care for vulnerable patients.
The Centers for Medicare and Medicaid Services (CMS) should target fraudulent hospices. We have provided guidance to CMS on our recommendations to do so with precision, including but not limited to identifying red flags such as those below, which should be applied with clinical context and should not be applied mechanically to penalize providers serving complex patient populations.
- High live discharge rate
- Low or no volume of in-person visits by hospice professionals
- Long average length of stay
- Unfavorable Hospice Care Index
- Lack of participation in Hospice Quality Reporting Program
- Limited or no provision of all four levels of hospice care
- Multiple hospices registered to one address
- Administrators and physicians overseeing numerous hospices
- Frequent changes in ownership
- Criminal activity in owner/administrator background check
We urge CMS to ensure their actions are precise and avoid implementing regulations that may burden mission-driven hospice organizations. Actions such as imprecise audits and chasing clerical errors while withholding justified payment interferes with care delivery to those who need it most and is harming hospice organizations who provide quality, patient-centered care. We look forward to providing detailed comments on the methodology of the new CMS scoring system in the Fiscal Year 2027 Hospice Wage Index and Payment Rate Update proposed rule, to ensure it accurately distinguishes fraudulent actors from providers managing clinical complexity.
AAHPM is committed to listening to and advocating for the priorities and concerns of our more than 5,000 members who deliver serious illness care every day. We do this through our work to evaluate and comment on regulation and legislation affecting hospice care when appropriate and empowering healthcare professionals and the public to identify both quality and fraudulent hospice care. Through this work, we aim to protect the strengths of the hospice benefit in order to ensure dignity, compassion and choice are always present when people living in the United States face the end of their lives.