Earlier this year, I had the opportunity to attend a community theater production of the iconic musical “Fiddler on the Roof.” In a series of unforgettable scenes, Tevye, the production’s main character, makes difficult family decisions by artfully balancing opposing views before choosing his path.

“On the one hand,” he intones, then ruminates on the important role tradition must play in the life of his village and family. “On the other hand,” he counters thoughtfully, then acknowledges that the inevitability of change must be factored into every decision.

I’ve recalled Tevye’s internal monologue many times since May, when the Centers for Medicare and Medicaid Services (CMS) announced a six-month national moratorium on enrolling new hospice agencies in Medicare. 

LeadingAge supports the short-term hospice moratorium, as do many of our members. However, some LeadingAge members strongly oppose it. We understand both viewpoints and have done our best to follow Tevye’s example by balancing them as we respond to CMS’ action.

On the one hand, we fully support the administration’s goal of preventing further attacks on programs that protect the vulnerable. LeadingAge believes, without hesitation, that there is no place in the hospice sector for bad actors or fraudulent activity. Abusing benefits designed to serve people in their final stage of life is inexcusable and must be stopped. 

On the other hand, we recognize that the hospice moratorium could harm some hospice providers and the people they are committed to serving. Agencies already enrolled in Medicare can continue providing hospice services during the enrollment pause. However, they cannot pursue new plans to expand into other markets or open a new office, including in rural areas that desperately need their services. This is a serious problem for legitimate providers who were planning new initiatives but had not yet applied for enrollment when the moratorium began. 

On the one hand, we believe that reforming the agency enrollment process will prevent bad actors from entering and exploiting the hospice system. We also believe that cracking down on hospice fraud will benefit legitimate providers by restoring public trust in the hospice sector.

On the other hand, we share your concern that CMS could extend this six-month moratorium, thereby worsening the challenges legitimate providers face. A moratorium is a blunt oversight tool; we are asking for precision going forward. We have urged CMS to use these six months wisely to develop and implement much-needed reforms. We strongly oppose any extension of the moratorium. In fact, we’ve recommended specific, targeted oversight strategies to screen newly enrolled providers more effectively and identify bad actors. These strategies can be implemented by the end of this six-month moratorium. 

Hospice is just one of our concerns. We’re also focused on CMS’ short-term moratorium on new home health agency enrollments, announced in May, and on proposed changes to provider enrollment in the CY 2027 home health rule. These changes go beyond what we recommended and could harm legitimate providers across the Medicare program. I’ll address these issues in my September blog. In the meantime, I encourage you to urge CMS to adopt a balanced approach to provider enrollment and, importantly, to be transparent about its expectations for all Medicare providers. 

It’s easy to feel helpless as we navigate the current program integrity landscape. Please don’t give in to these feelings. Instead, take concrete steps to help the hospice sector emerge stronger from this period:

Let your light shine. You are very good at what you do. Be proud of it. Make sure others know it. 

Be accountable. CMS’ enhanced scrutiny can ensnare even high-quality providers. That’s why it is important to follow CMS rules to the letter. Keep your paperwork in order. Let your careful, ethical business practices demonstrate to regulators and consumers that you are a cut above the competition. 

Become a role model. Help members of your community understand what a good hospice provider looks like. Make sure they know how you live out your mission by delivering high-quality services and compassionate care, and by going beyond basic hospice requirements to offer meaningful community programs, such as grief camps for children who have lost loved ones. 

LeadingAge’s message to CMS is simple: Let’s root out bad providers, but not in a way that hampers legitimate providers who are dedicated to delivering high-quality care. 

We want consumers to trust the hospice sector again. We want them to have easy access to high-quality hospice services. Finally, we want CMS to fully support legitimate providers as it works to achieve these goals.

We will not rest until these dreams become reality.