Update: CMS Response to Arizona Hospice

by Tim Rowan | Aug 7, 2026 | Admin, Advocacy, CMS, Hospice, Waste Fraud and Abuse

by Tim Rowan, Editor Emeritus

Update: CMS Sides with NGS in Arizona Hospice Case

Letter Says "Typos Count"

We are sad to have to report that CMS has rejected the evidence that a hospice’s report of change of ownership was due to a typo. The consultant retained to help with their appeal received this letter.

The CMS Letter

Thank you for your email. Based on our review, we do not see any issues with the revocation decision. The provider did file a reconsideration, and on May 6, 2026, we issued a decision upholding the 42 C.F.R. § 424.535(a)(8)(ii) revocation. Their main argument is that there was no change in ownership and, as a result, they should not have been subject to PPEO. However, the applications submitted by the provider clearly reflected 100% changes in ownership. In addition, the provider had an 80% PPEO claim denial rate, and none of these denials were overturned on claim appeal. Please note that the provider filed an appeal with the ALJ on June 18th. Given that the case is pending, we should not take any other action until the appeal has concluded.

Best Regards,

Anaga Nmagu, JD.
Director, Division of Provider Enrollment Appeals
Provider Enrollment & Oversight Group
Center for Program Integrity
Centers for Medicare & Medicaid Services
Office: (410) 786-4690
Email: anaga.nmagu1@cms.hhs.gov

Home Health and Hospice Respond

The more stories we can collect about CMS contractors overstepping their authority, improperly denying claims, up to and including putting honest providers out of business, the more convincing we will be when we confront the perpetrators. We urge you to tell us your stories. We will never publish your name.

If you, a client, or someone you know has stories about CMS contractors, please reach out to editor@therowanreport.com or tim@rowanresources.com.

# # #

Tim Rowan is a 33-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.com

©2026 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Formal NGS Complaint Submitted to OIG

by Tim Rowan | Jul 31, 2026 | CMS, Hospice, Medicare, Waste Fraud and Abuse

by Tim Rowan, Editor Emeritus

Formal NGS Complaint Submitted to OIG

Hospice Wrongly Subjected to PPEO Fights Back

Two weeks ago, we reported on an Arizona hospice that found itself in the middle of a revalidation survey when its Medicare Administration Contractor incorrectly classified it as a new provider. NGS placed the hospice under Provisional Period of Enhanced Oversight (PPEO) and promptly terminated its owners following a separate, 10-claim audit. (See “NGS Shutters Valid Hospice” – July 17)

According to this hospice’s PECOS file, no change of ownership — or any other triggering event that would justify reclassification — ever occurred. The error led to a clinical review of a handful of claims, a determination of fraudulent billing, and a 10-year ban against the owners.

On Monday, July 27, the hospice submitted a formal complaint to the Office of the Inspector General at HHS regarding NGS practices. According to the Medicare consultant retained by the hospice, the formal referral became necessary after a letter to CMS Administrator Dr. Mehmet Oz, describing multiple missteps by NGS, went unanswered. A subsequent video meeting with low-level CMS staff resulted only in a defense of the contractor.

Executive Summary

The hospice allowed us to publish a general summary of the complaint, provided we do not share its name at this stage. The OIG referral documents specific instances that the complainant asserts are representative of a “systemic pattern of misconduct by Medicare contractors.”

The complaint says that such misconduct “enriches contractors at the expense of providers and the Medicare Trust Fund.” It further notes that offending contractors continue to operate with CMS trust while the Center’s leadership remains focused only on a limited number of fraudulent providers.

Demand for Restitution and Reform

Dr. Mehmet Oz shifted uncomfortably in his chair, a look that signaled something between frustration and distress clouding his famous face. The new CMS Administrator removed his reading glasses, laid the Medicare consultant’s letter on his desk, thanked his aide for handing it to him, and asked her to close the door behind her as she left. Who he may have called next is anyone’s guess, but he did have a staffer tell the letter-writer, “We called the MAC; they said they didn’t do it.”

The complaint calls for meaningful reform that restores fairness to providers whose practices have been terminated. It demands restitution for owners who have been placed on the Preclusion List for ten years, often based on improper classifications.

The OIG referral specifically requests that:

CMS take immediate investigative action
All affected providers receive restitution with interest, and
CMS subject the entire contractor model to a thorough audit, similar in rigor to prior OIG reviews that uncovered widespread errors in contractor processes, some going back decades.

The complaint emphasizes that, while effective detection and elimination of actual fraud is essential, it must not come at the expense of compliant providers.

Strength in Numbers: Protect Your Agency

As we did in our first report of this series, we are opening our doors, well, our contact information anyway, to all Home Health and Hospice providers in the Medicare program. CMS may be able to ignore evidence from one or two providers, but a larger volume of consistent reports is harder to ignore. Write to us at editor@therowanreport.com, or Tim@RowanResources.com. If putting your story in writing makes you nervous, call me at 719-499-8902. You have seen how I protect the identity of the two providers outlined in this story. I will do the same for you.

We also have ways to help you find assistance to write your own OIG complaint. Once we get 100 or more complaints submitted, we will have status to demand Congressional hearings. You can be part of the solution.

# # #

Tim Rowan is a 33-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.com

©2026 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

NGS Shutters Valid Hospice

by Tim Rowan | Jul 17, 2026 | Breaking News, CMS, Hospice, Medicare

Will a Typo Shut Down Your Agency?

by Tim Rowan, Editor Emeritus

This is the first of a multi-part, investigative report about fraud, waste, and abuse by federal contractors. A Medicare consultant’s in-depth research found that some MACs may be guilty of worse fraud than the providers Dr. Oz talks about.

July 24 Update

The story below is evolving almost on a daily basis. On Monday, the hospice described in last week’s story will submit a formal complaint against NGS to the Office of the Inspector General in the Department of Health and Human Services. This move is in response to the apparent choice by CMS not to pursue accusations of impropriety by the victim hospice. We will publish the full details as soon as the OIG receives the complaint. In the meantime, we are gathering similar stories from other providers who may have experienced the same abuse by their MAC. Our contact information is at the end of this story.

It Was Supposed to be Routine

Every year, hospices submit revalidation paperwork to keep their Medicare enrollment current. For one unlucky Hospice in Phoenix, however, a paperwork glitch during that process triggered something far more sinister: classification as a “new provider” under the Provisional Period of Enhanced Oversight (PPEO) rules.

No ownership change

There was just one problem. Ownership had not changed since June 2019, as the PECOS enrollment record proved. On November 24 and 25, 2025, the hospice’s authorized officials sent NGS (their Medicare Administrative Contractor) clearly stated emails with an organizational chart attached. It showed that, as of July 13, 2026, official ownership records established in 2019 remained unchanged.

Even more telling: A CMS representative personally instructed the agency to write “Not a new agency” with its established date on the cover sheets of every Additional Documentation Request (ADR) form returned to NGS. NGS’s own auditors received forms bearing that exact, handwritten notation.

NGS received the message…and ignored it.

What is PPEO Fraud Prevention?

The consultant working with the Arizona hospice explained, “PPEO exists for one narrow purpose: enhanced prepayment review of claims from genuinely new providers, or those with qualifying ownership changes. It is not a post-payment cudgel to be applied retroactively to an established hospice’s existing charts to manufacture a “pattern or practice of abusive billing” under 42 C.F.R. § 424.535(a)(8).”

Yet that is exactly what happened, he told us.

NGS abandoned what the record suggests was a far more robust 54-chart review and instead conducted a lightning-fast, 10-chart PPEO “snapshot” over a mere 30-day period. Next, they denied eight claims, on a Post-payment rather than the PPEO standard Pre-payment review, looking back four months to November 2025. The denied claims totaled $54,568.42.

Grounds for denial bordered on the frivolous:

“missing” addendum forms, which are not required
hyper-technical formatting nitpicks
outright misrepresentations of the hospice’s medical record.

The consultant did not fail to notice NGS’s deceptions. Still falsely claiming there was a change of ownership, the MAC selected claims from a previous month before the non-existent ownership change.

The Clinical Reality NGS Ignored

Each of the eight patients had valid election statements. Addenda were either timely furnished via DocuSign (with irrefutable certificates of completion) or expressly declined by the beneficiary on the election form itself. Physician Certifications of Terminal Illness contained detailed narratives tying primary diagnoses — end-stage heart failure (NYHA Class IV), sarcopenia, senile degeneration of brain, end-stage MDS, advanced COPD — to synergistic comorbidities.

Objective prognostic indicators far exceeded LCD L33393 thresholds: PPS scores of 40–50%, 5/6 to 6/6 ADL dependence, MUAC measurements of 22–27 cm confirming severe malnutrition, serial weight loss, FAST progression to stage 6e–7A, incontinence, recurrent infections, oxygen or transfusion dependence (hemoglobin as low as 5).

Deadly consequences

In at least two cases, the beneficiary died within days or weeks of the service period — one during the benefit period itself, another just 37 days later. This is not “abusive billing.” This is hospice care for patients whose prognoses were tragically accurate.

Yet NGS’s initial denials were bare codes (commonly 55H1L or similar) with zero explanation — violating the regulatory requirement that determinations be written so a beneficiary can understand the reasons. At redetermination, new and contradictory theories emerged: one claim denied after NGS invented a “151-pound weight loss” when the chart showed a radically different number of pounds; another claimed “good appetite” while records documented clear decline.

These shifting rationales, and the refusal to engage the provider’s detailed page-by-page roadmaps mapping every regulatory element to the actual medical record pages, directly violate MLN Matters SE1521 and 42 C.F.R. §§ 405.921, 405.956, and 405.976.

Widely Known, Ongoing Issue

This case is not unique but is representative of the dilemma Medicare providers have faced since the early years of this century. The OIG has already issued reports documenting NGS’s systemic failures. Inspectors reopen cost reports after finding “obvious errors” by NGS, They have uncovered hundreds of thousands in net overpayment accusations, as well as 100% error rates in some desk-reviewed cost reports.

It does not speak well of the entire Medicare program that a contractor this error-prone in its accounting work was somehow trusted to make life-or-death clinical judgments and ownership determinations. Worse, the Milwaukee-based insurance company with the MAC contract rarely admits errors but instead doubles down, aggressively pursuing termination when caught in the act.

When the consultant fighting for the hospice could not shake loose satisfactory responses from NGS, he escalated. He managed to arrange a video conference with member of Dr. Oz’s staff. The conversation centered around hundreds of pages of documented contractor misconduct, including the “Not a new agency” notations NGS itself had accepted. Their response?

“We called the MAC and they said they didn’t do that.”

The case has now moved beyond Maximus QIC reconsideration. A master supplemental submission was filed this week (July 13–14, 2026) demanding reversal of all eight denials and a declaration that the PPEO was unlawful from day one. Protective ALJ hearings have been filed. A DAB appeal on the related enrollment revocation is pending. Federal court is the next stop if necessary.

This entire 2025-26 incident does not signal new behavior, but has been going on nearly 20 years. It is the exact pattern the Medicare Appeals Council condemned in Quality Home Health Services, Inc. v. Trust Solutions, LLC (DAB, Sept. 14, 2009) — a case in which NGS itself was the intermediary whose “very brief and conclusory,” “stock phrase,” non-individualized denials were rejected wholesale.

Sound Familiar?

As this is written, the Arizona hospice’s saga progresses toward a federal trial or a pre-trial settlement. We will stay on top of developments for future reports.

Administrator Oz, and the HHS OIG, may respond to NGS behavior by initiating measures to curb contractor fraud, or he may continue to stand before TV cameras to keep his focus on bad actors on the provider side. Neither consultants nor the press hold the power to influence CMS one way or the other.

United front

That will be up to the provider community. It will be up to you, dear reader. If anything like the Arizona experience happened to your agency at the hands of your MAC, please tell us. We will share your stories, anonymously if requested. The more stories we can deliver about insurance companies with CMS contracts that engage in lawbreaking, the more difficult it will be for top officials to ignore it. The most powerful evidence is first-person stories about improper MAC determinations that result in harm to a patient. Send your stories to editor@therowanreport.com.

More to Come

We are still receiving additional information on this breaking news story. We are communicating with the consultant involved and will have more information next week. Some of what we have learned game changing. Stay tuned.

# # #

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He is also the creator of the new “Home Care Technology Buyer’s Guide,” which will be released in the 4th quarter this year. More information: RowanResources.com
Tim@RowanResources.com

©2026 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Solutions Provider Expands Home Health Footprint

by Kristin Rowan | May 29, 2026 | M&A

by Kristin Rowan, Editor

Solutions Provider Expands Home Health Footprint

An Interview with Mike Scarbrough

LivTech may not be a name with which you are familiar. I wasn’t. But, you are likely familiar with the brands this private equity firm has acquired. Worldview reduces document processing time for home health and hospice agencies. Qualis manages DME workflows for hospice agencies. Ally handles invoicing, payments, and record-keeping for 1099 caregivers while keeping registries aligned with regulations. And now, LivTech has acquired Alora, the cloud-based full workflow solution for home health, hospice, and home care.

Why Alora?

CEO Mike Scarbrough, who saw a lot of industry growth when working in the ambulatory space, got excited about the post acute market. LivTech has now been operating in the care at home space for a while with their acquisitions of Worldview and Thornberry. With that foothold, the company looked to have a significant presence in home health, tie all their care at home products together, and provide their customers with a migration path forward, Scarbrough said.

Alora is built for home health, hospice, and home care

“In home health and home care, a lot of our customers are or are contemplating doing both. We hear a lot that choosing different solutions for home health, home care, and hospice is difficult. We have a suite of products that will do all three after the integration, which will take months, not years,” Scarbrough said. “The Alora platform was very purpose-built, has a rich feature set, has consistently high NPS scores, and has very low churn. More importantly, Alora has a great personality and culture fit with LivTech.”

What to Expect

I asked Scarbrough what the future holds for LivTech as the integration finalizes and what LivTech and Alora customers should expect. He explained that LivTech offers solutions, not software. Their software platforms form the foundation, but their customers also get support, road maps, and best practices.

“The people we work with are care oriented, as they should be. We want to take the work they do and make it easier so they can focus on what matters, patient care.”

Mike Scarbrough

CEO, LivTech

The Path

To make the job easier for the caregivers, LivTech takes what they know as technologists and applies that to what they understand about home health. This involves ambient transcription, chart summaries, drift notification, audits and surveys, and information flow. They also use their understanding of home health to know where NOT to insert their technology: between the caregiver and the care. The solutions augment care and make suggestions, but never make decisions about care.

AI and the Future of LivTech

The question asked of every solution provider, technologist, and consultant recently is “What about AI?” Scarbrough noted the dramatic changes in the AI tool chain in the last six months, changing the pace of software development. He said these changes are going to make some things obsolete and push developers to focus less on how the tech works and more on the problem their trying to solve. We will rely more on expert problem solvers than on tech experts. Scarbrough predicts exponential growth in what software can do, real solutions that weren’t possible before.

When I asked how he felt about the future of LivTech after the acquisition of Alora, he said:

“I’m super excited and motivated to grow the business. The people we sell to and the people who work for us continue to amaze with their commitment and passion for the work they do.”

# # #

Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Medicare Moratoria

by Kristin Rowan | May 14, 2026 | Breaking News, Medicare, Regulatory, Waste Fraud and Abuse

by Kristin Rowan, Editor

Medicare Moratoria

CMS Halts All New Home Health & Hospice Agencies

As part of it’s ongoing efforts to curb Medicare waste, fraud, and abuse, the Centers for Medicare and Medicaid Services (CMS) is taking a bold step. On Wednesday, May 13, 2026, CMS announced a 6-month moratoria on home health and hospice agency enrollment. Aimed at protecting Medicare beneficiaries and taxpayer dollars, the moratoria will temporarily stop new enrollment of providers in home health and hospice, which CMS calls “high-risk” categories and key sources of fraudulent activity. CMS states this effort builds on additional fraud prevention initiatives, including enhanced screening, site visits, and expanded oversight activities across the hospice and home health sectors

More Investigations

Together with Vice President JD Vance’s Anti-Fraud Task Force, CMS will increase its targeted investigations of hospice and home health agencies that are suspected of fraud. CMS promises to use advanced data analytics and to accelerate the removal of fraudulent hospice and home health agencies.

Skirting Authority

CMS investigations revealed that some agencies intent on committing fraud are closing their businesses and reopening under different names in different states to perpetrate additional fraud. The moratoria will prevent these agencies from skirting authority in this manner. Additionally, the moratoria applies to some changes in ownership, which is a common technique used to hide these “bad actors.”

What it Means for You

The moratoria do not apply to existing providers with current enrollments. You can continue to deliver services to Medicare beneficiaries as long as your enrollment is current and in good standing.

Statement from CMS

“We’ve seen systemic and deeply troubling fraud in the hospice and home health space, with bad actors exploiting some of our most vulnerable Medicare patients and stealing money from the American taxpayer. Today we’re shutting the door on fraud—preventing new bad actors from entering Medicare while we aggressively identify, investigate, and remove those already exploiting them. This is about protecting patients, restoring integrity, and safeguarding taxpayer dollars.”

Dr. Mehmet Oz

Administrator, Centers for Medicare and Medicaid Services

More Information

The administration’s anti- fraud, waste, and abuse efforts are ongoing.

Read the CMS Press Release

Full text of the Home Health Moratorium

Full text of the Hospice Moratorium

# # #

Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Enhabit Sells Out to PE

by Kristin Rowan | Feb 26, 2026 | M&A

by Kristin Rowan, Editor

Enhabit Sells Out to PE

Kinderhook proposes billion dollar deal

Enhabit Home Health & Hospice announced this week they agreed to be acquired by Private Equity company Kinderhook industries. Enhabit has 247 home health and 115 hospice locations across 34 states. Stockholders will receive $13.80 per share from the publicly traded company after the acquisition is final and the company will longer be listed on the stock exchange. The stock buyout is reportedly just shy of 25% more than the stock value as of the close of business on February 20th.

Enhabit History

Enhabit made headlines in 2025 and again earlier in February surrounding its lawsuit against Chris Walker, Vistria Group, and Nautic Partners. In 2024, Encompass and Enhabit sued the parties for breach of duty when the principles involved created VitalCaring while still serving as senior officers for Enhabit. Enhabit, the former home health and hospice division of Encompass Health, collected $43 million in attorneys’ fees and mitigation damages on February 12, 2026.

Enhabit’s registered mission is A Better Way to Care®. The company purpose is to provide high-quality, compassionate care to every patient. Their core values and fundamental beliefs guide their behaviors and actions.

Deciding to Sell Out

“Following a thorough evaluation and extensive deliberations in consultation with our independent advisors, we are pleased to reach this agreement with Kinderhook. The Board evaluated the current state of the business, its outlook and opportunities, and is confident this transaction maximizes value for our stockholders and is in their best interest.”

Jeffrey W. Bolton

Chairman of the Board of Directors, Enhabit

CEO Barb Jacobsmeyer said the agreement is a “terrific outcome” for stockholders, clinicians, caregivers, patients, and families, citing resources and expertise that will come from Kinderhook. Meanwhile, Chris Michalik, Managing Director at Kinderhook said the company admires Enhabit’s leadership, patient-centered culture, and strong market position.

Pending Approval

Enhabit’s Board of Directors unanimously approved the acquisition. However, the deal still awaits approval from stockholders and regulatory bodies. Enhabit has scheduled a special meeting of stockholders for the vote. In conjunction with the SEC filing, some Enhabit executive officers filed a customary voting and support agreement, meaning they have granted proxy voting rights to Kinderhook. It is almost certain the acquisition will be approved by both companies. Only the regulatory approval is unknown.

# # #

Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Purpose-Built AI for Care at Home

by Rowan Report | Jan 15, 2026 | Artificial Intelligence, Home Health, Hospice, Outcomes

by Isaac Greszes, Eleos

Purpose-Built AI for Care at Home

How Care at Home leaders can move beyond AI pilots

Care at Home is increasingly turning to AI to address documentation burden, clinician burnout, and regulatory pressure. While AI has the potential to address these issues and more, practical results remain uneven, leaving agencies with a lot of experimentation, but little clarity on actual value.

Evaluating AI solutions should focus on real-world outcomes, how the solution fits into your existing workflow, whether the software is scalable, and how it handles changing regulations. You should also look for AI solutions that are built for care at home (purpose-built). This series of articles will help you make informed, risk-aware decisions about AI adoption.

AI is Coming Fast

Home health and hospice leaders are navigating a difficult balance: persistent workforce shortages, rising provider burnout, expanding documentation requirements, and increasing regulatory scrutiny — all within thin operating margins.

At the same time, AI has moved quickly from experimental to strategic. Many organizations are now evaluating AI not just for productivity, but for operational and administrative efficiency, clinician experience, compliance readiness, and financial performance.

And the stakes are high

Early results across the market have been inconsistent. Some organizations report meaningful reductions in administrative burden and a clear return on investment. However, others struggle to find value after adoption. The difference often lies not in whether AI was adopted, but how it was designed, supported, and governed.

The pilot problem

As AI adoption accelerates, many organizations find themselves caught in extended pilot cycles — testing multiple tools without committing to the operational changes required for scale. While pilots can validate technical feasibility, they rarely provide the consistency or measurement discipline needed to demonstrate sustained ROI in regulated care at home environments.

Quality over Quantity

Why the right evidence matters

In today’s AI market, product demonstrations are easy to produce. Documented outcomes are not.

Executive leaders should expect vendors to demonstrate real-world impact, supported by customer data, third-party validation, or peer-reviewed research. Credible AI partners should be able to explain how their results translate to care at home — and where limitations exist. The challenge is not the lack of information from pilots, but the lack of evidence those pilots results can be reproduced, measured, and sustained, in a care at home setting.

Objective Evidence that Matters

When evaluating AI platforms, leaders should look for evidence related to:

Documentation efficiency, such as reduced time per visit or faster note completion
Operational ROI, including quicker billing readiness or reduced rework
Compliance support, such as documentation completeness or audit preparedness
Provider experience, including reduced perceived administrative burden
Care outcomes, including patient engagement and satisfaction

AI solutions can impact efficiency and burnout. But, these outcomes are highly dependent on whether the solution was built for care at home, the quality of implementation, how easily it will integrate into your workflow, and governance. If a vendor cannot explain how results were achieved and whether they are reliable and repeatable outside the pilot, the vendor and the solution should be evaluated carefully.

General Purpose AI

And inconsistent results

Many AI tools marketed to healthcare organizations rely on general-purpose language models designed for tasks like summarization, chat, or content generation — not for producing structured clinical notes aligned to regulatory and reimbursement requirements.

Home health and hospice documentation often includes:

Clinical observations made in non-clinical environments
Structured requirements tied to reimbursement and regulation
Risk-sensitive language related to safety, decline, or end-of-life care
Significant variation across disciplines, visit types, and patient contexts

Where generic AI breaks down

In these settings, AI tools based on general-purpose language models introduce risks related to accuracy, hallucinations, bias, privacy, and workflow fit — because they were not designed to operate within structured clinical, regulatory, and reimbursement frameworks.

In practice, organizations report that the additional oversight required to validate or correct AI-generated output can reduce — or even negate — anticipated efficiency gains, limiting adoption and ROI. As a result, organizations often remain stuck in pilot mode — investing time and effort in validation without achieving the scale or consistency required for meaningful return.

The right question

When evaluating an AI solution, the right question is not whether the AI tool can record a conversation and translate it into notes or whether the tool can reduce documentation, but whether it can consistently support high-quality clinical documentation at scale without increading burden or creating compliance risks.

Purpose-Built AI

What it means and why it drives operational impact

In care at home environments, purpose-built AI should be evaluated less as a point solution and more as foundational infrastructure — one designed to support regulated clinical workflows consistently over time.

Many AI platforms label themselves as “purpose-built,” but leaders must look past marketing language to truly scrutinize the way the technology is designed and deployed. In regulated clinical environments, purpose-built AI typically incorporates:

Domain-specific clinical intelligence, informed by real documentation patterns
Provider involvement in defining structure, logic, and validation criteria
Structured outputs aligned to required note components, in addition to free-text summaries
Grounding mechanisms that reduce fabricated or misattributed content
Privacy-conscious data handling, with explicit limits on data retention and reuse

Research consistently shows that providers prefer AI systems that function as collaborative tools — preserving human oversight while reducing administrative load — rather than fully automated systems that completely bypass clinical judgment. These characteristics directly affect whether AI improves documentation time, supports compliance workflows, and earns provider trust — all prerequisites for driving ROI.
These design choices are what allow AI systems to move beyond experimentation and begin delivering durable efficiency, compliance support, and clinician adoption at scale.

# # #

This article is part 1 in a 4-part series. Come back next week for “Scalability, Security, and Governance.”

About Eleos

At Eleos, we believe the path to better healthcare is paved with provider-focused technology. Our purpose-built AI platform streamlines documentation, simplifies compliance and surfaces deep care insights to drive better client outcomes. Created using real-world care sessions and fine-tuned by our in-house clinical experts, our AI tools are scientifically proven to reduce documentation time by more than 70% and boost client engagement by 2x. With Eleos, providers are free to focus less on administrative tasks and more on what got them into this field in the first place: caring for their clients.

©2026 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

What can Providers Give to Patients, Part 7

by Elizabeth E. Hogue, Esq. | Dec 12, 2025 | Admin, Clinical, Legal

by Elizabeth E. Hogue, Esq.

What Providers can Give to Patients

Providers, including marketers, are tempted to give patients and potential patients free items and services. While providers usually have good intentions, they must comply with applicable requirements.

Read Parts 1-6

OIG Advisory Opinion

This article provides an example from OIG Advisory Opinion No. 09-11 that shows how the OIG applies exceptions described in this series of articles.

A Case Example

The request for this Advisory Opinion was submitted by a hospital that provides free blood pressure checks to anyone who requests the service during certain hours. The hospital said that it does not advertise free blood pressure checks, which are provided by a member of the nursing staff who follows specific guidelines and procedural checklists.

The hospital also said that free blood pressure checks are not conditioned on use of any other goods or services from the hospital or any other particular provider. No discounts are offered for follow-up services. Recipients of blood pressure checks are advised to see their own practitioners when results are abnormal. The hospital does not bill any payor, including the Medicare and Medicaid Programs, for this service.

OIG Analysis

In its analysis, the OIG first referenced the exception for preventive services described in Part 5 of this series.

The OIG then pointed out that the fair market value of this service, especially if recipients use the service more than once, may exceed the limits of $15 per service or $75 per year described in Part 2 of this series. Therefore, said the OIG, the services may constitute a kickback.

According to the OIG, blood pressure checks are preventive services. The key question, however, is whether the free care promotes the provision of other, non-preventive care reimbursed by the Medicare and/or Medicaid Programs.

Is It Promotional?

In this case, the OIG said that it is unlikely that free blood pressure checks will result in the provision of other services. The factual basis for this conclusion in the Advisory Opinion was that the hospital did not:

Make appointments with its practitioners for individuals with abnormal results
Offer individuals discounts for additional covered services
Otherwise promote its particular programs

Crafted with Care

“In sum,” said the OIG, “the Arrangement is appropriately crafted so as to avoid improper ties to the provision of other services…For these same reasons, we conclude that we would not impose administrative sanctions arising in connection with either the anti-kickback statute or the CMP on the Hospital in connection with the Arrangement.”

Final Thoughts

The 7 parts of this series describe and summarize the laws and exceptions to providing incentives, gifts, and help to patients in accordance with the Anti-Kickback Statute and the Civil Monetary Penalties Law. As long as you are following these regulations, providers should certainly use all of the exceptions available to them to provide better quality of care for patients.

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Elizabeth Hogue is an attorney in private practice with extensive experience in health care. She represents clients across the U.S., including professional associations, managed care providers, hospitals, long-term care facilities, home health agencies, durable medical equipment companies, and hospices.

No portion of this material may be reproduced in any form without the advance written permission of the author.

Hospice Carve-In is Out

by Rowan Report | Nov 25, 2025 | Advocacy, Hospice, Medicare, Medicare Advantage, Partner News, Regulatory

FOR IMMEDIATE RELEASE

Contact: Hannah Kristan
communications@allianceforcareathome.org
202-355-1647

Sen. Marshall and Sen. Whitehouse Issue Letter to Senate Leadership Expressing Bipartisan Support for Policies that Preserve Medicare’s Hospice Benefit Under Original Medicare

Alexandria, VA and Washington, D.C., November 24, 2025. On November 20, Senator Roger Marshall (R-KS) and Senator Sheldon Whitehouse (D-RI) sent a letter to Senate leadership expressing strong bipartisan support for policies that preserve the Medicare Hospice Benefit under Original Medicare, including for Medicare Advantage (MA) beneficiaries, which has protected their access to high-quality, timely end-of-life care for nearly three decades.

Repeal Special Rule

As Congress considers potential reforms to the MA program, the letter urges Senate leadership to maintain this critical safeguard and oppose any proposals that would include hospice in the Medicare Advantage program, including repeal or alteration of the Special Rule for Hospice (the Special Rule), also known as hospice carve-in.

Hopice in MA

Despite years of attempts from Congress, the Alliance strongly opposes efforts to integrate hospice into Medicare Advantage (MA). Past attempts have revealed challenges such as administrative burdens, difficulty creating networks, and delayed payments for claims. Bringing hospice under Medicare Advantage would undermine patient choice, adversely impact timely access to care, and fragment the hospice experience for patients and families at a highly vulnerable time.

View the full letter here.

Excerpt

“MA enrollees who elect hospice currently retain the freedom to choose any Medicare-certified hospice provider, free from network limitations or prior authorization requirements. More than half of hospice beneficiaries pass away within 14 days of election, making delays in care both harmful and unacceptable. Integrating the hospice benefit into MA plan design would jeopardize this access by layering additional managed care terms (or policies) on top of an already managed and coordinated benefit.”

Marshall and Whitehouse

U.S. Senators

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“The Alliance thanks Sen. Marshall and Sen. Whitehouse for listening to the concerns of the care at home community and taking action to protect our nation’s most vulnerable patient population by defending the Hospice Benefit under original Medicare,” said Scott Levy, Chief Government Affairs Officer at the Alliance. “The Alliance will continue to lead on this important public policy priority for hospice providers nationwide by advocating to preserve this sacred promise established by Congress and kept on behalf of the American people for over four decades.”

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About the National Alliance for Care at Home

The National Alliance for Care at Home (the Alliance) is the leading authority in transforming care in the home. As an inclusive thought leader, advocate, educator, and convener, we serve as the unifying voice for providers and recipients of home care, home health, hospice, palliative care, and Medicaid home and community-based services throughout all stages of life. Learn more at www.AllianceForCareAtHome.org.

© 2026. This press release originally appeared on the National Alliance for Care at Home Website and is published with permission. For additional information or for permission to print, please see press contact above.

What Can Providers Give to Patients, Part 5

by Elizabeth E. Hogue, Esq. | Nov 25, 2025 | Admin, Clinical, Legal

by Elizabeth E. Hogue, Esq.

What Can Providers Give...

Recap

Providers, including marketers, are tempted to give patients and potential patients free items and services. While providers usually have good intentions, they must comply with applicable requirements.

Part 1

As Part 1 of this series indicates, there are two applicable federal statutes: the Anti-Kickback Statute (AKS) and the Civil Monetary Penalties Law (CMPL). Part 1 also makes it clear that there are a number of exceptions. If providers meet the requirements of applicable exceptions, they can give patients and potential patients free items and services that would otherwise violate applicable requirements.

Part 2

Part 2 describes an exception for items and services of nominal value with a retail value of no more than $15 per item or $75 in the aggregate per patient on an annual basis that may be given by providers to beneficiaries. Providers may not, however, give cash or cash equivalents.

Part 3

Part 3 describes the circumstances under which providers may give free items and services to patients with demonstrated financial need.

Part 4

Part 4 summarizes recent guidance from the Office of Inspector General (OIG) about giving incentives to promote vaccination against COVID-19.

Care & Services

According to the OIG, providers may also give patients free preventive care items or services. The definition of remuneration under the CMPL regulations excludes incentives given to patients/potential patients to promote the delivery of preventive care services so long as the delivery of such services is not directly or indirectly related to the provision of other services reimbursed in whole or in part by the Medicare Program or other state and federal healthcare programs. Preventive services include:

Prenatal services or postnatal well-baby visits, or specific clinical services described in the current U.S. Preventive Services Task Force’s Guide to Clinical Preventive Services
Services that are reimbursable in whole or in part by the Medicare Program, or other federal and state care programs

Incentives

However, incentives related to preventive services may not include:

Cash or instruments convertible to cash
Incentives of value that are disproportionally large in relationship to the value of the preventive care services in terms of either the value of the services or the future health care costs reasonably expected to be avoided as a result of preventive care

Preventive

Any tie between provision of exempt covered preventive care services and covered services that are not preventive may, therefore, violate the CMPL and the AKS.

The OIG has stated that some free or discounted services may fit within the preventive care exception described above. These services may include free blood sugar screenings and cholesterol tests.

Anti-Kickback Exceptions

The AKS does not include an exception similar to the provisions of the CMPL described above. In commentary to Supplemental Compliance Guidance for Hospitals, however, the OIG said:

From an anti-kickback perspective, the chief concern is whether an arrangement to induce patients to obtain preventive care services is intended to induce other business payable by a Federal health program. Relevant factors in making this evaluation would include, but not be limited to: the nature and scope of the preventive care services; whether the preventive care services are tied direct or indirectly to the provision of other items or services and, if so, the nature and scope of the other services; the basis on which patients are selected to receive the free or discounted services; and whether the patient is able to afford the services.

Final Thoughts

Based upon the above, the OIG is unlikely to challenge the provision of free preventive services given to patients and potential patients, under either the CMPL or the AKS, so long as the above requirements are met.

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Elizabeth Hogue is an attorney in private practice with extensive experience in health care. She represents clients across the U.S., including professional associations, managed care providers, hospitals, long-term care facilities, home health agencies, durable medical equipment companies, and hospices.

No portion of this material may be reproduced in any form without the advance written permission of the author.