Part 2 of 2 in The Exploitation of Compassion series. Read Part 1: Hospice, Comfort Care, and Palliative Care, What to Know
Warning signs every family should know
In one Los Angeles office building, state records show 112 separately licensed hospice agencies sharing a single address. Within a mile of that building, 210 hospice agencies were active at the same time. No legitimate explanation accounts for that density. It is the footprint of an industry built to extract Medicare payments, not to care for dying people.
Our companion article explained what hospice, comfort care, and palliative care actually mean, and why the difference matters. This article covers the other half: how the fraud actually happens, what it looks like from the outside, and exactly what to do if you suspect your loved one has been pulled into it.
A System Built to Be Exploited
Most hospice agencies provide ethical, medically appropriate end-of-life care to people who genuinely need it. The concern in this article is not hospice itself. The concern is fraudulent enrollment, and the abuse of a benefit designed for patients with a real terminal illness.
Medicare pays hospice agencies a flat daily rate for every enrolled patient, regardless of how much care that patient actually receives on a given day. A hospice that enrolls a relatively healthy person who needs almost no attention collects that daily payment anyway. The incentive is not subtle: the more people on the census, the more revenue, whether or not those people are dying.
California became the proving ground for what happens when that incentive meets weak oversight. A 2022 California State Auditor report found that Los Angeles County experienced a 1,500 percent increase in hospice agencies since 2010, reaching more than six and a half times the national average number of agencies relative to its aged population. The audit identified building after building where dozens of separately licensed hospice companies shared the same suite, the same hallway, sometimes the same office.
State auditors flagged this kind of clustering as a direct fraud indicator, because the number of agencies in these areas likely exceeds the number of patients who genuinely need services. Fraud schemes uncovered in these investigations have shown that some operators were able to obtain hospice licenses and bill Medicare despite having little evidence of meaningful clinical operations, real staff, or real patients.
How One Operation Worked
Documented Case · U.S. Department of Justice
Topanga Hospice Care: $300 a Month in an Envelope
Lolita Beronilla Minerd, a licensed vocational nurse, operated Topanga Hospice Care Inc. from 2020 to 2025. Federal prosecutors allege she billed Medicare more than $9.17 million for hospice services to beneficiaries who were not terminally ill. Topanga’s non-death discharge rate, the share of patients who left hospice alive rather than through death, was approximately 85 percent. The national average is 17.2 percent.
One married couple told investigators they were approached at a market and asked if they wanted to sign up. Minerd and three Topanga employees later visited the couple at home and promised that everything would be free, and that each of them would receive $300 a month. The money came delivered in an envelope: $600 in cash, every month, for six months. Neither beneficiary had a terminal illness. Their own physician confirmed it.
In a related case charged the same week, Gladwin and Amelou Gill, who owned 626 Hospice Inc., doing business as St. Francis Palliative Care, are accused of paying illegal kickbacks for the referral of patients who were not dying, and submitting more than $5.2 million in fraudulent claims for hospice services that were not medically necessary or were never provided.
Source: U.S. Attorney’s Office, Central District of California, “8 Arrested in Health Care Fraud Takedown” justice.gov
Notice what is absent from this story: no doctor’s referral, no clinical assessment, no terminal diagnosis. The recruitment happened at a market. The enrollment happened at a kitchen table. The only thing required was a signature and a willingness to take the money.
The Cost of Unnecessary Billing
Recruitment fraud is only one piece of it. Federal auditors have also found widespread billing abuse within hospices that do have real patients, specifically around General Inpatient Care, the highest-paying tier of the hospice benefit, reserved for patients in acute crisis who need round-the-clock symptom management.
Medicare pays roughly $1,200 a day for General Inpatient Care, compared to about $230 a day for routine home care. An OIG audit found that nearly a third of GIP stays nationwide had no documented medical necessity for that level of care, costing the program over $268 million in a single audited year. A patient does not need to be misled into thinking they qualify for hospice for this kind of fraud to happen. They can be a real hospice patient, correctly enrolled, while the agency bills Medicare at the most expensive tier available for care the patient never actually needed.
Warning Signs to Watch For
Signs of Predatory Hospice Enrollment
Unsolicited contact. A real hospice referral comes from a treating physician after a clinical evaluation. It is not sold at a grocery store, a health fair, a church event, or door to door.
Free gifts tied to a signature. Offers of cash, groceries, housekeeping, nutritional shakes, or medical equipment in exchange for enrolling are illegal kickbacks under federal law, not generosity.
No real medical evaluation. Legitimate hospice enrollment requires physician certification of a terminal illness. Be cautious if enrollment paperwork appears before any meaningful medical evaluation occurs, or if no one reviews your loved one’s actual medical history or talks to their existing doctor first.
Pressure to sign quickly. Legitimate hospice decisions involve time to ask questions, read paperwork, and consult family. Urgency is a sales tactic, not a medical one.
An unfamiliar agency on a Medicare statement. If a hospice name appears on a Medicare Summary Notice or Explanation of Benefits that your family did not choose, treat it as a fraud alert, not a clerical error.
Missing or absent care. For someone legitimately enrolled, red flags include skipped nursing visits, no contact over weekends or holidays, and care that does not match the written plan.
Medicare Summary Notices Are Often the First Clue
Most families discover hospice fraud the same way Lynn Ianni did: by reading a denied claim, not by catching a recruiter in the act. Review every Medicare Summary Notice or Explanation of Benefits your loved one receives. If you see any of the following, treat it as a potential fraud alert and investigate immediately.
- A hospice agency on the statement that your family does not recognize
- Hospice claims appearing when no one in your family requested hospice care
- Home health or hospice services billed that your loved one never actually received
Catching this early is often the difference between a quick correction and months without coverage.
If You Suspect Fraud, Act Quickly
Five Steps to Take Right Away
Call the Senior Medicare Patrol. SMPs are federally funded programs that specifically help beneficiaries disenroll from fraudulent hospice and restore standard coverage, often within days.
Review every Medicare Summary Notice. Look for any hospice or home health provider you do not recognize, and check it against what services were actually delivered.
Contact your loved one’s actual physician. Confirm directly whether they certified a terminal diagnosis. If they did not, that enrollment was not legitimate.
Report it to the HHS Office of Inspector General. The OIG hotline takes tips on suspected Medicare fraud and can open a federal investigation.
File with your state’s Medicaid Fraud Control Unit if your loved one is dual-eligible for Medicaid. MFCUs have direct authority to investigate and prosecute.
The Federal Response
In May 2026, CMS imposed a six-month nationwide moratorium on new hospice and home health Medicare enrollments, with heightened oversight in states identified as elevated fraud risk, including California, Texas, Arizona, Nevada, Georgia, and Ohio. The agency also announced a new public hospice scoring system intended to help families identify agencies with troubling patterns of quality or billing before they sign anything. The moratorium does not affect existing legitimate enrollments or a beneficiary’s right to choose hospice care when it is genuinely needed and appropriately certified.
This is a meaningful response to a documented crisis, but a federal moratorium does not undo enrollments that already happened, and it will not catch every bad actor immediately. Family vigilance remains the most reliable protection available right now.
If you have not already, read Part 1 of this series: Hospice, Comfort Care, and Palliative Care, What to Know. It walks through exactly what each term means, what hospice election legally changes about your Medicare coverage, and the questions every family should ask before signing anything.
Questions Every Family Should Ask
What terminal diagnosis qualifies my loved one for hospice?
Which physician certified that eligibility, and did our own doctor take part in that decision?
What treatments will Medicare no longer cover once we sign?
Can I have a copy of every document before signing, so I have time to read it?
How do we revoke hospice if our circumstances or goals of care change?
Who do I call if I disagree with the eligibility determination?
Where to Go From Here
You are not alone in this. Advocates exist who do this work alongside families every day, and these resources are a place to start.
Signs of Nursing Home Abuse and NeglectWhat to watch for beyond the obvious red flags How to Report Nursing Home AbuseEvery reporting channel, step by step, including the Long-Term Care Ombudsman program in your state CMS Ratings ExplainedHow to read a facility’s inspection history before you choose a placement Law Firm DirectoryFind attorneys who handle elder care and Medicare fraud cases Mobile NotaryGet advance directives and power of attorney documents notarized- California State Auditor, Report 2021-123, “California Hospice Licensure and Oversight” bsa.ca.gov
- U.S. Attorney’s Office, Central District of California, “8 Arrested in Health Care Fraud Takedown” justice.gov
- CBS Los Angeles, “Justice Department announces federal charges in Southern California health care, hospice fraud investigation” cbsnews.com
- HHS Office of Inspector General, “Hospice” portfolio oig.hhs.gov
- CalMatters, “California’s hospice fraud epidemic is locking seniors out of the care they need” calmatters.org
- CMS Newsroom, “CMS Announces Aggressive Nationwide Crackdown on Fraud” cms.gov
- STAT News, “Medicare halts enrollment of new hospice, home health providers” statnews.com
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