With increasing regulatory scrutiny, home health and hospice organizations are facing increasing pressure to stay ahead of audits, denials and shifting policy priorities.
At the 2025 Axxess Growth, Innovation and Leadership Experience (AGILE), Jason Bring, Partner at Arnall Golden Gregory LLP, and Patrick Harrison, Senior Director of Regulatory and Compliance at National Alliance for Care at Home, discussed the current regulatory landscape, spending trends, compliance challenges and provided strategies for success.
Increasing Regulatory Scrutiny
Regulations in hospice and home health are growing more rigorous, emphasizing fraud prevention and thorough patient documentation.
“We’re seeing more and more spending on hospice, outpacing home health now,” Bring said. “We’re returning to pre-COVID levels with over 50% of our patient base utilizing the hospice benefit.”
Bring highlighted the importance of understanding the MedPAC numbers.
“According to MedPAC, about 2.7 million beneficiaries are using home health in the Medicare fee-for-service benefit,” Bring explained.
Balancing Survey and Audit Preparedness
Organizations must balance survey and audit preparedness to ensure compliance and avoid financial penalties. Many organizations assume that strong survey performance means they are audit-proof but that’s a misconception.
Bring shared a client’s experience of receiving a perfect survey but getting a $450,000 denial. Despite the good survey results, the denial came from an audit by a supplemental medical review contractor.
“Just because you’re compliant with the conditions of participation doesn’t mean you’re meeting the conditions of payment,” Harrison explained.
Consistent and Detailed Documentation
Consistent and detailed documentation is important for hospice and home health organizations when caring for long-term patients with conditions such as Alzheimer’s and dementia.
“The main focus for me is Alzheimer’s,” Bring noted. “That’s where we see the most problems with documentation because they’re on for so long and different caregivers are involved.”
Auditors look for consistency. Copying and pasting notes or making typos can trigger a deeper investigation.
Provisional Period of Enhanced Oversight
The Centers for Medicare and Medicaid Services (CMS) Period of Enhanced Oversight (PPEO) is expanding, and organizations must be vigilant to avoid overregulation and exclusion from programs.
“The PPEO is quick to jump on an issue and can put great operators in a concerning situation,” Harrison said.
Organizations should monitor regulatory developments closely and begin preparing. Waiting could result in exclusion from Medicare programs.
Proactive Compliance
To thrive in this high-stakes environment, organizations must shift from reactive to proactive.
“You never get a second chance to make a good first impression,” Bring said. “Package your records in a very organized format to reduce denials from the start.”
“We need to document effectively with the mindset of getting paid and train our staff appropriately,” Harrison added. “Keep yourself from getting denials in the first place, so that you don’t have to hire consultants and attorneys to go through that process.”
With more than 550 attendees, more than 50 sponsors and countless connections made, AGILE 2025 was a massive success for everyone. Click here to register for AGILE 2026, May 4-6 in Dallas.
