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CMS Targets Hospice Providers With Prepayment Reviews in Six States

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Summary

CMS Medicare Administrative Contractors have been conducting expanded prepayment reviews (EPRs) of existing hospice providers since September 2024 in Arizona, California, Nevada, and Texas. As of December 2025, hospices in Georgia and Ohio have also been added to the review program. Husch Blackwell attorneys discuss how hospices can differentiate EPRs from other audit types, what to expect throughout the process, and strategies to overcome claim denials.

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What changed

CMS has expanded its Expanded Prepayment Review program to include hospice providers in six states. Since September 2024, MACs have been reviewing existing hospice providers in Arizona, California, Nevada, and Texas, with Georgia and Ohio added as of December 2025.\n\nHealthcare compliance officers overseeing hospice operations in these states should monitor audit activity closely, ensure claims documentation is thorough, and develop strategies to respond to potential claim denials. The podcast advises hospices to understand how EPRs differ from other audit types and to prepare for the review process proactively.

What to do next

  1. Monitor EPR developments in Arizona, California, Nevada, Texas, Georgia, and Ohio
  2. Prepare documentation to support hospice claims during prepayment review
  3. Review audit response strategies with compliance staff

Archived snapshot

Apr 15, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

April 15, 2026

Hospice Insights Podcast - High Risk Hospices Are in the Hot Seat Across Six States

Husch Blackwell LLP + Follow Contact LinkedIn Facebook X Send Embed Since September 2024, CMS’s Medicare Administrative Contractors have been conducting expanded prepayment reviews (also known as “EPRs” or targeted high-risk reviews) of existing hospice providers in Arizona, California, Nevada, and Texas. As of December 2025, hospices in Georgia and Ohio are also under the microscope. In this episode, Husch Blackwell attorneys Bryan Nowicki and Zaina Niles discuss how hospices can differentiate between EPRs and other audit types. You’ll also learn what to expect throughout the EPR process and See more + Since September 2024, CMS’s Medicare Administrative Contractors have been conducting expanded prepayment reviews (also known as “EPRs” or targeted high-risk reviews) of existing hospice providers in Arizona, California, Nevada, and Texas. As of December 2025, hospices in Georgia and Ohio are also under the microscope. In this episode, Husch Blackwell attorneys Bryan Nowicki and Zaina Niles discuss how hospices can differentiate between EPRs and other audit types. You’ll also learn what to expect throughout the EPR process and strategies to overcome claim denials and other possible EPR consequences. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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Last updated

Classification

Agency
Husch Blackwell
Published
April 15th, 2026
Instrument
Notice
Legal weight
Non-binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Healthcare providers
Industry sector
6211 Healthcare Providers
Activity scope
Hospice care services Medicare billing Prepayment review response
Geographic scope
United States US

Taxonomy

Primary area
Healthcare
Operational domain
Compliance
Topics
Medicare and Medicaid Regulatory Compliance

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