Program Integrity

my patients

The Alliance is committed to strong, targeted efforts to prevent fraud, waste, and abuse across federal healthcare programs.  

Any fraudulent activity in home health, hospice, or home and community-based services (HCBS) is a threat to patients and legitimate providers who are operating in good faith. The Alliance has always worked closely with lawmakers and regulators to ensure the ideals at the heart of these care models are upheld in the practice of care. 

Care at home providers put patients’ values, wishes, and goals first. For providers to continue to deliver on this promise, we need policies and regulations in place to ensure: 

  • Oversight strategies remain focused on risk-based enforcement – identifying and removing fraudulent entities without undermining legitimate providers delivering high-quality care 
  • Deterrence strategies ensure bad actors cannot enter the care at home space 
  • Local, state, and federal agencies have the capacity to set and enforce licensure and certification requirements 
  • Patients and families understand their benefits and have access to the quality care they deserve 
  • Providers strive to deliver above and beyond the requirements of Medicare and Medicaid 

As Alliance members continue to take an active role in program integrity initiatives and conversations, members are encouraged to visit the Program Integrity Alliance Member Resource page to stay prepared, engaged, and informed. 

Recommendations from the Alliance

On March 30, the National Alliance for Care at Home (the Alliance) submitted a letter to Dr. Mehmet Oz, Administrator of the Centers for Medicare & Medicaid Services (CMS), regarding the Request for Information related to Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH).

The Alliance, LeadingAge, LeadingAge California, and the California Association for Health Services at Home (CAHSAH) in a March 25, 2026 letter to CMS commend the agency’s actions to protect Medicare beneficiaries, preserve the integrity of the hospice and home health benefits, and root out bad actors who are exploiting the program and harming patients and families. At the same time, the associations emphasized the need for a carefully targeted federal response to protect current and prospective patients, and preserve access to care delivered by trustworthy providers.

In late 2025, the Alliance submitted detailed recommendations to CMS outlining data-driven, risk-based strategies to strengthen program integrity in Medicare home health and hospice.  

In early 2026, the Alliance submitted a comprehensive set of program integrity recommendations to CMS Administrator Dr. Oz in response to increasing concerns around the country regarding instances of fraud in Medicaid funded services.

The Alliance – and its preceding legacy organizations – have been advocating for program integrity since 2019. Notably for hospice care, in 2022, the organizations worked collaboratively to develop and vet a detailed list of 34 program integrity recommendations, which built on provisions of the HOSPICE Act that were already being implemented. Since then, over half of the measures have been implemented, but the Alliance carries forward this important work as more measures are needed to protect the patients and families who depend on quality care and the legitimate providers who deliver it.

Member Resources

Members, explore the Program Integrity Alliance Member Resource page to stay prepared, engaged, and informed.

Moratorium Resources

On May 13, CMS announced a six-month nationwide moratorium on the enrollment of new home health agencies and hospice providers into Medicare, as part of the Agency’s crackdown on fraud in these benefits. See the Agency’s press release. CMS cites concerns regarding fraudulent billing activity and geographic concentrations of suspect activity as the basis for nationwide. See the Alliance’s analysis.  

The Alliance strongly opposes a nationwide moratorium, and we have instead advocated for targeted, tailored program integrity measures to protect beneficiaries and the Medicare Trust Fund without restricting access in regions where legitimate provider growth is needed to meet patient demand. We are both concerned and alarmed at CMS’s action, given the heightened concentration of fraudulent activity in certain geographic regions, and the lack of nationwide data supporting such an approach. A blanket nationwide moratorium risks penalizing legitimate providers operating in good faith and limiting beneficiary choice, without addressing existing fraudulent actors already operating in these benefits. See the Alliance’s press release

The following resources can help members understand and respond to the national moratorium announcement.

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