The FBI Just Published the Hospice Fraud Playbook. Make Sure Your Intake and Marketing Don’t Look Like It.

On June 3, 2026, the FBI’s Internet Crime Complaint Center issued a public service announcement — alert number I-060326-PSA, “Emerging Hospice Fraud Targeting Medicare Recipients” — warning patients and families about hospices that enroll people who are not dying. It reads like consumer protection. For a legitimate operator, it is something else: a published, plain-English list of the exact behaviors federal investigators are now hunting for — arriving the same week CMS has roughly 800 Los Angeles–area hospices and home health agencies under payment suspension and the DOJ is filing criminal charges.

The single most useful thing you can do with that alert is not forward it to your patients. It is to read it the way an auditor would, point your finger back at your own operation, and confirm that nothing you do at intake, in marketing, or in your referral relationships could be mistaken for what the FBI just described. This post turns the alert into a self-audit.

What the FBI Actually Said

The PSA describes an “emerging” scheme in which fraudulent operators enroll Medicare beneficiaries into hospice for services they do not need — sometimes without the patient’s knowledge — and then bill Medicare for care that is unnecessary or never delivered. The specific tactics the FBI calls out:

• Door-to-door solicitation. Recruiters approach beneficiaries directly, often offering free home services such as house cleaning or meal delivery that are conditioned on signing up with a specific hospice.
• Enrollment incentives. Gift cards, cash, and other “too good to be true” offers used to get a signature.
• Recruiter bonuses tied to enrollment. Payment to marketers based on the number of beneficiaries signed up.
• Enrollment without knowledge or need. Beneficiaries who are not terminally ill — in some cases who never agreed to anything — appearing on a hospice census.
• Falsified medical documentation created to justify an eligibility determination that the patient’s actual condition does not support.
• Billing for services not rendered.

The alert tells consumers to guard their Medicare number from anyone who shows up unsolicited, to refuse incentive offers, to check a provider on Medicare’s Care Compare, to read their Medicare Summary Notices for care they never received, and to report suspected fraud to ic3.gov or 1-800-MEDICARE (1-800-633-4227).

Why an Alert Addressed to Patients Is Really Aimed at You

A public warning like this does two things at once. It recruits 65 million Medicare beneficiaries as fraud reporters, and it publishes — for free — the indicator list investigators are working from. Every red flag the FBI hands a patient is a red flag a data analyst, a UPIC, or a federal prosecutor is already screening for.

It does not land in a vacuum. It lands on top of an enforcement wave this blog has been tracking all spring: the Qlarant payment suspensions that began at 447 California hospices in April and grew to roughly 800, the nationwide six-month enrollment moratorium, and a string of Los Angeles criminal cases. In one widely reported June takedown, federal prosecutors charged more than a dozen defendants — including nurses and hospice owners — in an alleged scheme that paid healthy people to pose as terminally ill, with reported losses around $50 million. (Figures here are as reported by the Department of Justice and news outlets; the underlying cases are ongoing.)

Legal experts covering the sector have landed on the same advice: in this climate, legitimate hospices need “bulletproof” compliance, because the cost of looking like a bad actor — a payment suspension with no appeal and months of frozen cash flow — now falls on clean providers too. The point of the self-audit below is to make sure your records answer the question before anyone asks it.

The Self-Audit: Eight Things to Check in Your Own Operation

Take each behavior in the FBI alert and turn it into a question about your own hospice. If you cannot answer cleanly with documentation, that is your first project.

1. How do patients actually find you?

Map your real referral sources for the last 90 days. Legitimate hospice referrals come from physicians, hospitals, SNFs, assisted living, and families — not from a marketer knocking on doors in a neighborhood. If anyone representing your agency is doing unsolicited, in-home consumer outreach, stop it today. Door-to-door solicitation of beneficiaries is the first tactic the FBI names, and there is no clean version of it.

2. Does anything of value change hands to get an election?

Gift cards, cash, free housekeeping, free meals, free transportation, waived costs — anything offered to a beneficiary to induce them to choose your hospice can violate the federal Anti-Kickback Statute and the Beneficiary Inducement CMP. The bar is low: routine items must be of nominal value and cannot be tied to choosing your agency. Audit what your community liaisons hand out and what your intake team promises.

3. How are your marketers and liaisons paid?

Per-admission bonuses, per-head commissions, or census-based incentive pay for anyone who touches referrals or enrollment is exactly the “recruiter bonuses tied to enrollment” pattern the FBI flags — and it is a long-standing kickback risk. Move marketing compensation to fixed salary or to structures that fit a recognized safe harbor, and have counsel review the plan.

4. Can you prove informed consent at every election?

Pull your last ten election statements. For each, confirm a valid signature from the patient or authorized representative, the date, and evidence that the person understood they were electing the Medicare hospice benefit and waiving curative treatment for the terminal condition. “Enrollment without the patient’s knowledge” is the allegation that turns a billing dispute into a fraud case. Your consent trail is the rebuttal.

5. Does the clinical record support the terminal prognosis — independently?

For those same charts, confirm a physician narrative that explains why the prognosis is six months or less, a certifying physician who actually reviewed the patient, and a timely face-to-face encounter where required. The fraud cases hinge on “falsified documentation” and patients who were not dying. The defense is real, contemporaneous, clinically defensible eligibility documentation — not a template narrative copied across admissions.

6. Does what you billed match what you delivered?

Spot-check claims against visit records and the plan of care. Every billed day and every level of care should be backed by documented services that actually happened. “Billing for services not rendered” is the last item on the FBI’s list and the easiest to catch in your own data before someone else does.

7. Are your referral and ownership relationships documented?

Legal experts expect the next enforcement wave to scrutinize referral and ownership structures. Medical director agreements, arrangements with physicians who refer, and any common ownership across referring entities should be in writing, at fair market value, commercially reasonable, and not volume-based. If you cannot produce the contract, assume it is a finding.

8. What does your public profile say about you?

The same alert points patients to Care Compare, and the same claims data feeds CMS’s analytics. Your live discharge rate, your length-of-stay distribution, your level-of-care mix, and your SSVI score are visible to any analyst who runs your CCN. Know your own numbers before an investigator does — if any of them read as an outlier, have the operational explanation ready.

The Marketing Gray Zone Most Operators Don’t Think About

Most legitimate hospices are not running a door-to-door scam. The risk for good operators is subtler: ordinary marketing tactics that, viewed by a skeptical investigator in 2026, resemble the alert. A few worth re-examining:

• “Free in-home assessments” promoted directly to consumers. A clinical evaluation on a physician referral is care. An unsolicited offer marketed to seniors to get into the home is closer to the pattern the FBI describes. The difference is who initiated it and whether a clinician ordered it.
• Gifts and meals for referral sources. The classic catered in-service is everywhere in this industry, but anything beyond nominal value — or anything that looks like it is buying referrals — is exposure under the Anti-Kickback Statute.
• Liaison bonus plans. “Everybody pays marketers on volume” is not a defense. It is the specific structure named in both the kickback statutes and the FBI alert.
• Aggressive census growth with no referral story. If admissions are climbing and you cannot point to the physicians and facilities driving them, your own data will eventually ask the question for you.

None of these are automatically illegal. All of them are worth a documented, counsel-reviewed answer right now, while the answer is cheap.

What to Do This Week

1. Read the actual alert. Send I-060326-PSA to your compliance officer and your administrator and walk the eight points above against your operation.
2. Pull your intake scripts and marketing materials. Strip out anything that offers a beneficiary something of value, anything that implies free non-covered services for choosing you, and anything that reads as unsolicited consumer solicitation.
3. Audit marketer compensation. Identify any per-admission or census-based pay and get it reviewed before the next pay period.
4. Chart-audit ten recent admissions for consent, eligibility documentation, face-to-face timeliness, and billing-to-visit alignment. Fix the gaps and standardize the fix.
5. Inventory referral and ownership relationships and confirm each has a current, written, fair-market-value agreement.
6. Know your outlier numbers. Check your live discharge rate, length of stay, and SSVI score so you are not learning them from a suspension letter.

Further Reading

• From 447 to 800: The LA Suspension Wave Nearly Doubled
• Got a Qlarant “Notice of Suspension”? The 15-Business-Day Rebuttal Playbook
• The Live Discharge Rate Trap: How to Check Yours Before You’re Next
• CMS Just Froze New Hospice Enrollments Nationwide
• FBI/IC3 Alert I-060326-PSA — Emerging Hospice Fraud Targeting Medicare Recipients

The Bottom Line

The FBI did not write this alert for you, but it told you exactly what it is looking for. In a year when a payment suspension arrives without warning and without an appeal, the operators who come through clean are the ones whose intake, marketing, comp plans, consent records, and eligibility documentation already look nothing like the playbook the government just published. Treat I-060326-PSA as your audit checklist, not your customers’ reading material. The work is cheap this week and very expensive after a letter shows up.