By Robin Heffernan
The Centers for Medicare & Medicaid Services (CMS) has proposed new measures to strengthen hospice oversight and increase transparency across providers. It is an important and necessary step — and a clear signal that CMS is responding to growing concerns around hospice fraud and program integrity.
But if we are serious about hospice fraud prevention, transparency alone is not enough. The next step is ensuring that these efforts translate into real-time, actionable guidance that protects patients and taxpayers before harm occurs.
Medicare spends more than $20 billion annually on hospice care, serving approximately 1.7 million beneficiaries. Yet hundreds of millions of dollars are likely lost each year to fraud, abuse, and low-quality providers. More importantly, patients and families are often left to make urgent, high-stakes decisions without clear, reliable information about hospice provider quality.
CMS’s focus on hospice transparency and oversight is well placed. Greater visibility into ownership, operations, and performance will make it harder for bad actors to operate undetected and will strengthen the foundation for enforcement.
What CMS Proposed — Hospice Transparency and Provider Scoring
CMS’s proposal introduces a set of new tools designed to better identify hospice providers that may warrant closer scrutiny.
At the center is a new Service and Spending Variation Index (SSVI) — a provider-level scoring system derived from claims data. The SSVI evaluates patterns such as long hospice lengths of stay, live discharges and re-enrollment, levels of routine home care, and non-hospice spending during hospice enrollment.
CMS plans to publicly report these hospice quality signals and use them to flag providers with potential program integrity risks.
In parallel, CMS is expanding hospice transparency through provider-level reporting and introducing consumer-facing indicators on Care Compare for hospices that fail to meet Hospice Quality Reporting Program (HQRP) requirements. These measures are paired with continued targeted enforcement in high-risk states.
Taken together, this represents a meaningful shift in CMS hospice oversight.
CMS is creating clearer signals — signals that can help identify outliers, focus enforcement, and bring visibility to a part of the healthcare system that has historically lacked it.
But these signals, by design, are retrospective and probabilistic. They surface patterns of concern after they emerge and guide further review.
That is directionally right — and in many ways, aligned with what the system has needed for some time.
The key question now is how this is implemented in practice — and whether it can be executed and maintained at the speed, fidelity, and usability required to truly guide decisions in real time.
Signals alone do not guide decisions at the moment a patient is choosing a hospice provider. And they do not continuously adapt in a way that allows the system to get ahead of harm.
The opportunity now is to take what CMS is building and make it actionable — to evolve from identifying risk to actively guiding better decisions in real time.
If fully realized, this type of scoring system could become exactly what the hospice ecosystem has been missing — a trusted, continuously updated reference point for quality.
The difference will come down to execution. Whether the right metrics are used to truly distinguish high- from low-quality providers. Whether the data updates frequently enough to reflect real-world performance. And whether these insights are delivered where they matter most — embedded in referral workflows and visible to patients and families before they make a decision.
Those details will determine whether this becomes a compliance tool, or a true decision system.
From Hospice Transparency to Real-Time Fraud Prevention
Hospice oversight today remains fundamentally retrospective. It looks backward in a system where bad actors are operating in real time — entering markets, scaling quickly, and profiting before meaningful action is taken.
By the time issues are surfaced, patients and families may already have experienced harm, and taxpayer dollars have already been spent.
If the goal is true hospice fraud prevention, we have to move earlier.
We need the ability to distinguish high-quality hospice providers from poor performers at the moment decisions are made — not months or years later.
That requires more than transparency. It requires a continuously updated, real-time view of hospice quality.
A practical way to think about this is a “Blue Book” for hospice: not a static rating system or annual report, but a living infrastructure that is constantly measuring, updating, and informing decisions. One that helps guide referrals toward high-quality hospice providers, continuously monitors performance, and identifies outliers before patterns of harm can scale.
This is how you prevent fraud instead of chasing it.
Importantly, the building blocks for this already exist.
CMS already has access to a robust set of hospice quality data that, when combined thoughtfully, can differentiate high-performing providers from those that warrant closer scrutiny. Measures such as live discharge rates, gaps in nursing visits, caregiver experience, and care patterns near the end of life are not abstract indicators — they are real signals of quality and risk.
A Constructive Path Forward for CMS and Hospice Quality
Earlier this week, we shared a memo with CMS outlining how a system like this can be operationalized in practice: establishing a national, continuously updated hospice performance infrastructure — a real-time system that enables better decisions at the point of care, continuous monitoring of hospice providers, and earlier identification of bad actors.
The intent is not to add reporting burden, but to better use existing CMS data.
This is where public and private efforts can align.
CMS is strengthening hospice oversight and transparency. In parallel, there is an opportunity to operationalize these advances into tools that are dynamic, continuously updated, and usable in real-world decision-making — by patients, providers, and payers alike.
The path forward does not require reinventing hospice oversight. It requires activating it.
CMS has taken an important step. The next step is to build on that foundation with continuous, real-time hospice quality intelligence that can get ahead of fraud rather than respond to it.
If we do that, we can create a system that protects patients, safeguards taxpayer dollars, and ensures hospice delivers what it is meant to provide: more good days.
Robin Heffernan is Co-Founder and CEO of Empassion Health, a company focused on improving care for people living with serious illness through high-quality, home-based palliative and hospice services. She works with health plans, providers, and policymakers to advance more transparent, accountable models of care — with the goal of helping patients have more good days.
