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K3 Analytics · Deep Dive #2

The 89-Hospice Building

Medicare hospice has quietly become a $28 billion-a-year program, and a startling share of it flows through a stretch of the San Fernando Valley where one office plaza is the registered address of 89 different hospice companies. Here's how end-of-life care became the second great fraud bonanza of American healthcare.

K3 Analytics · April 15, 2026

109 → 1,841
Licensed hospice agencies in Los Angeles County, 2010 → 2021 — a 1,589% increase in eleven years.
Source: California State Auditor Report 2021-123 (March 2022)

If you want to see what a Medicare fraud bubble looks like in physical form, drive to a stucco-fronted office plaza in Van Nuys called the Merabi Professional Medical Plaza. State licensing records identify 89 separate hospice companies at that single three-story building — a number CBS News confirmed by visiting in person and finding not 89 actual offices, but mostly empty suites and a few clusters of unmarked doors. Federal regulators logged nearly 400 violations at 75 companies housed there between 2021 and 2025. The building owner now says only twelve hospice tenants remain.

That building isn't the worst of it. Drive a few miles in any direction and you'll find streets where hospices outnumber coffee shops. Assemblymember Alexandra Macedo has reported finding 197 hospices registered to one address in the same neighborhood. Within four blocks of one part of Van Nuys, the current CMS Administrator counted forty-two hospice licenses. The California State Auditor, in a March 2022 report that has been criminally underread, found 112 different licensed hospice agencies sharing a single physical address.

Hospice was supposed to be the small, mission-driven part of American medicine. It was created in 1982 as a Medicare benefit modeled on the British charity hospices: comfort care, in the home, for the last six months of a terminal illness. Nonprofits ran it. Volunteers staffed it. Today, half of all Americans who die in the United States die enrolled in hospice. The benefit costs Medicare $28.2 billion a year. About 80% of all hospices are now for-profit, and as Ava Kofman wrote in ProPublica's prize-winning "Endgame" series: "Easy money and a lack of regulation transformed a crusade to provide death with dignity into an industry rife with fraud and exploitation."

What follows is a tour of how it happened, where the dollars went, and what the federal government is finally trying to do about it.

Medicare Hospice Spending ($ Billions, 2010–2024) $0B $6B $12B $18B $24B $30B 2010: $12.9B Medicare hospice spending $12.9 2010 2014: ~$15.1B $15.1 2014 2016: ~$16.7B $16.7 2016 2018: ~$19.0B; OIG portfolio report flagged vulnerabilities $19.0 2018 2019: $20.9B $20.9 2019 2020: $22.1B $22.1 2020 2021: $23.0B $23.0 2021 2022: $23.7B; California State Auditor report exposes 1,500% LA County hospice growth $23.7 2022 2023: $25.7B; CMS imposes Provisional Period of Enhanced Oversight in CA, NV, AZ, TX $25.7 2023 FY 2024: $27.5B / CY 2024: $28.2B — 10.1% growth, fastest acceleration in a decade $28.2 2024 Sources: MedPAC March 2025 Report; CMS Hospice Monitoring Report April 2025  ·  Hover bars for detail

How a per diem turned into a per-kilo gold rush

The fraud here is not subtle. The mechanics fit on a napkin.

Medicare pays a hospice a flat daily per diem for every day a beneficiary is enrolled, regardless of whether anyone from the hospice actually shows up that day. The standard rate — "routine home care," which accounts for roughly 99% of hospice days — is about $225 a day for the first sixty days. A patient enrolled for a year generates roughly $82,000 in Medicare payment, whether the hospice provides daily nursing visits or twenty minutes a week.

To enroll a patient, all you need is a doctor willing to certify the patient as terminally ill with a prognosis of six months or less "if the disease runs its normal course." That phrase — "if the disease runs its normal course" — is doing more work than any other six words in Medicare statute. For diagnoses like dementia, congestive heart failure, or "failure to thrive," prognosis is inherently subjective. The certifying physician usually works for the hospice. There is no independent review. The patient can be recertified indefinitely — and if the patient stubbornly refuses to die, the hospice can simply discharge them as "no longer terminally ill" and recertify them again later.

"It's an open secret that hospice is one of the poster children for fraud and abuse in Medicare." — David Grabowski, Harvard health policy professor and MedPAC commissioner, in ProPublica's "Endgame," November 2022

The rest of the business model writes itself. Find the patients. Get them enrolled. Bill the per diem. Repeat. The OIG and DOJ have documented operators paying "patient brokers" up to $1,300 per patient per month in kickbacks. They've documented marketers going door-to-door in low-income housing, recruiting people in Skid Row, and offering homeless or unhoused individuals $300 a month in cash to sign up. They've documented a 29-year-old pregnant woman in Mississippi who learned she had been enrolled in hospice only when her doctor ordered a routine blood test, and a 69-year-old denied physical therapy after a pickleball injury because scammers had used her Medicare ID to enroll her in hospice without her knowledge.

And then there is the business of the licenses themselves. About 200 hospice companies are currently for sale on commercial business-listing sites. Asking prices typically run $300,000 to $500,000. Listings include phrases like "Never billed hospice license for sale!" and "Brand New Hospice — Ready to bill!" The reason a never-billed license has value is the "CHOW loophole" — the Change of Ownership procedure. Buying an existing hospice's CMS Certification Number is faster and looser than going through full Medicare enrollment as a new applicant. CMS only closed this gap for hospices in January 2024, with a "36-month rule" prohibiting transfer within three years of initial enrollment.

Hospice Per Diem Economics: One Patient, One Year $0 $100K $200K $300K $400K Routine Home Care (RHC) full year: ~$82,125 in Medicare payment per patient at $225/day RHC full year $82K Inpatient Respite Care (IRC) full year: ~$189,400 at $519/day. Used for short respite periods, but if billed continuously generates this much. IRC full year $189K General Inpatient (GIP) full year: ~$427,000 at $1,170/day. Designed for short crisis periods. Routine GIP billing is the single highest-yield abuse pattern. GIP full year $427K Continuous Home Care (CHC) full year: ~$591,000 at $1,619/day. Designed only for acute crisis hours; if billed continuously generates this. CHC full year $591K California average payment per beneficiary 2023: $20,872 — 48% above national average of $14,110 CA avg / patient $21K National average payment per beneficiary FY 2024: $14,951 National avg / patient $15K Annualized Medicare payment, FY 2025 base rates  ·  Hover bars for detail
The arithmetic of recruitment. If a marketer signs up twenty patients at the routine home-care rate, the hospice generates roughly $122,000 a month in Medicare revenue. Even paying the marketer a five-figure kickback per head, the math still works. This is why the California State Auditor found new hospices coming online faster than the population was aging.

The four-county cluster

Medicare-certified hospices are not evenly distributed. They are wildly concentrated.

FraudGraph's copy of the CMS hospice provider file shows 2,155 Medicare-certified hospices currently operating in California — roughly twice as many as the second-place state (Texas, with 1,081), and more than the next eight states combined. California alone accounts for 31% of every Medicare-certified hospice in America. Two-thirds of those California hospices were certified after January 2019. More than half were certified after 2021.

Within California, the concentration is even tighter. Los Angeles County alone has more than 1,300 Medicare-certified hospices in FraudGraph's data — more than any state in the country except Texas. The two adjacent Inland Empire counties (Riverside and San Bernardino) add roughly another 225. Just across the border in Nevada, Clark County (Las Vegas and its suburbs) has 144 more, of which sixty-one were certified in 2023 or later — the exact pre-moratorium enrollment surge that prompted CMS to act. Maricopa County, Arizona (Phoenix) adds another 158. Together, these four metropolitan counties account for roughly 28% of every Medicare-certified hospice in the country, in geographic areas containing about 6% of the U.S. population.

Medicare-Certified Hospices: The Four-County Cluster vs. the Rest of the U.S. Los Angeles County: ~1,343 hospices (20.0% of all U.S. Medicare-certified hospices) San Bernardino + Riverside Counties (CA): ~223 hospices (3.3%) Maricopa County (AZ, Phoenix): 158 hospices (2.4%) Clark County (NV, Las Vegas): 144 hospices (2.1%) — 61 certified in 2023 or later All other U.S. counties combined: ~4,838 hospices (72.2%) Four-county share ~28% of U.S. hospices Los Angeles County — ~1,343 (20.0%) San Bernardino + Riverside — ~223 (3.3%) Maricopa County (AZ) — 158 (2.4%) Clark County (NV) — 144 (2.1%) All other U.S. counties — ~4,838 (72.2%) Hover slices for detail Source: FraudGraph CMS hospice general info, April 2026

The dollars follow the count. FraudGraph data shows that in 2023 alone, California Medicare hospice payments totaled $3.81 billion across 182,691 beneficiaries. The average California hospice patient generated roughly $20,900 in Medicare payment — about 48% above the national average of $14,110. The House Energy & Commerce Committee, citing CMS estimates, recently put the suspected hospice fraud in Los Angeles County alone at $3.5 billion. CMS itself has identified between 900 and 1,000 fraudulent hospices in LA County.

The buildings and addresses are public record. FraudGraph's snapshot of CMS data shows certified hospices clustered at addresses like:

AddressCityCMS-certified hospices at address
14545 Friar StVan Nuys, CA 914117
2600 Foothill BlvdLa Crescenta, CA 912144
127 S Brand BlvdGlendale, CA 912043
225 E BroadwayGlendale, CA 912053
401 N Brand BlvdGlendale, CA 912033
4119 W Burbank BlvdBurbank, CA 915053
18340 Ventura BlvdTarzana, CA 913563
12501 Chandler BlvdValley Village, CA 916073
Important caveat: Sharing an address with another hospice is not, by itself, evidence of wrongdoing. Many legitimate medical buildings host multiple practices. The numbers above are CMS-certified counts only and are dramatically lower than California state license counts at the same locations, because state licensing captures hospices that have been licensed but never enrolled in Medicare or have since had Medicare revoked. The named addresses are referenced as matters of public CMS record; no individual hospice tenant at any of these addresses is implicated in fraud here.

The recruiters and the doors they knock on

The most affecting parts of the public record aren't the spreadsheets. They're the recruitment scripts.

Federal court filings in the House of Angels case describe a marketing operation that misappropriated the names of physicians (including two who were already deceased) to certify patients as terminally ill. In the Nita Palma case, a Glendale woman who had previously been excluded from Medicare for kickback convictions purchased three hospices through her daughter and husband, and — according to federal prosecutors — continued operating them while she was awaiting trial, eventually directing her husband to open three more hospices and submit another $4.8 million in fraudulent claims after she was already incarcerated.

Ava Kofman's reporting in ProPublica's "Endgame" captured the recruitment pitch in unguarded language. A former AseraCare recruiter described the search:

"We'd find run-down places where people were more on the poverty line. You're looking for uneducated people, if you will, because you're able to provide something to them and meet a need." — Former AseraCare hospice recruiter, quoted in ProPublica, November 2022

In April 2026, California Attorney General Rob Bonta announced charges against 21 people in "Operation Skip Trace," a $267 million Medi-Cal hospice scheme in which prosecutors say the operators bought stolen personal information off the dark web and used it to enroll non-California residents into California Medicaid hospice. Per the complaint, not a single legitimate hospice service was provided over the life of the scheme. Days earlier, a separate federal operation called "Operation Never Say Die" arrested eight people in Southern California, including the owners of a hospice (626 Hospice / St. Francis Palliative Care) where federal investigators alleged a five-year patient survival rate of 97% — in a program designed for people with six months left to live.

For-profit growth, nonprofit decline

The shift from charity hospice to industrial hospice is documented in the financials. Twenty-five years ago, less than a third of U.S. hospices were for-profit. Today, around 80% are. Between 2019 and 2023, the for-profit count grew by roughly 1,400. The nonprofit count declined by about 100. Every net new hospice in America is a for-profit hospice.

The Cornell-led academic literature on private-equity-owned hospices reports that PE-owned hospices have the highest profit margins, the lowest spending on direct patient care, and significantly worse patient-experience scores than nonprofit and other for-profit hospices. Average length of stay also diverges sharply by ownership: nonprofit hospices average about 72 days per patient, while for-profit hospices average about 115 days. For dementia patients specifically, the gap widens to 187 days at for-profits versus 130 at nonprofits. Longer stays mean more per-diem days. More per-diem days mean more revenue.

For-Profit vs. Nonprofit Hospice: Key Operating Metrics 0 50 100 150 200 For-profit hospices: 115 days average length of stay per patient (2023) 115 Nonprofit hospices: 72 days average length of stay per patient (2023) 72 Avg LOS (days) For-profit dementia patients: 187 days average length of stay — the longest-stay diagnosis 187 Nonprofit dementia patients: 130 days average length of stay 130 Dementia LOS For-profit aggregate cap exceedance rate: 22.6% in 2022 (over half of California for-profits exceeded the cap) 22.6% Nonprofit aggregate cap exceedance rate: roughly 5% (low single digits) ~5% Above Medicare cap For-profit live discharge rate: ~22% (top decile of providers exceed 56%) 22% Nonprofit live discharge rate: ~13% 13% Live discharge rate For-profit Nonprofit
The cap is the canary. Medicare imposes an aggregate annual cap per beneficiary ($34,465 in FY 2025). Hospices that exceed it must repay the difference. 22.6% of all U.S. hospices exceeded the cap in 2022, up from 16.3% in 2018, and over half of California for-profit hospices did. The average over-cap repayment liability is around $419,000 per hospice. As MedPAC noted in its March 2025 report, $15.6 billion — over 60% of all hospice spending — goes to patients with stays exceeding 180 days, and roughly $5.8 billion goes to patients who have already received at least a full year of hospice care.

The enforcement record

The Department of Justice has been pursuing hospice fraud for years, but the pace and scale of cases through 2024–2026 represents something new. The headline cases below are all matters of public record — either guilty pleas, sentences, or settled allegations:

DateCaseAmountOutcome
Apr 2026Operation Skip Trace (CA AG, LA County, 14 hospices)$267M21 charged, 5 arrested
Apr 2026Operation Never Say Die (DOJ, So. Cal.)$50M+8 arrested incl. Palma re-arrest
Nov 2019Merida Group (Mesquias, McInnis et al., TX)$150MOwner: 20 yrs; CEO: 15 yrs
Oct 2025United Palliative & Hospice (Ogudo, Martinez, TX)$110M43-count indictment
Aug 2024Shaklian / Chateau d'Lumina (LA, gold-bar laundering)$54MPled guilty Jan 2026
Apr 2024Akula / Canon Healthcare (New Orleans)$42M20 yrs; jury conviction
Jul 2024Gentiva (formerly Kindred at Home)$19.4MFCA settlement, no admission
May 2025Fichidzhyan / House of Angels (Granada Hills)$17M12 yrs; 4 co-defendants
Aug 2025Palma (Glendale, excluded re-offender)$10.6M9 yrs; re-arrested Apr 2026
Jun 2025Creative Hospice / Abdsharafat (Atlanta)$9.2MFCA settlement, no admission
Apr 2024Primero / Beltran (Las Vegas)$7.1M33 mos each
Top Hospice Fraud Enforcement Actions (Alleged Loss / Settlement Amount) $0 $60M $120M $180M $240M Operation Skip Trace (Apr 2026): $267M alleged Medi-Cal hospice fraud, 21 charged, dark-web identity theft Skip Trace (CA AG) $267M Merida Group (Nov 2019): Owner Mesquias sentenced to 20 years, $120M restitution Merida Group $150M United Palliative & Hospice (Oct 2025): 43-count superseding indictment, 7 defendants, pending trial United Palliative $110M Shaklian / Chateau d'Lumina (Aug 2024): Pled guilty Jan 2026, laundered through $6M in gold bars Shaklian (gold bars) $54M Operation Never Say Die (Apr 2026): 8 arrests, includes Palma re-arrest and Gill family hospice (97% survival rate) Never Say Die $50M+ Akula / Canon Healthcare (Apr 2024): 23-count jury conviction, 20-year sentence, $42M restitution, GIP overbilling Akula (NOLA) $42M Gentiva / Kindred at Home (Jul 2024): FCA settlement, no admission of liability, resolved 9 qui tam suits Gentiva (settlement) $19.4M Petros Fichidzhyan (May 2025): 12-year sentence, hospice + home health fraud Fichidzhyan $17M Nita Palma (Aug 2025): 9-year sentence, was already excluded from Medicare; re-arrested April 2026 Palma (re-offender) $10.6M Creative Hospice / Abdsharafat (Jun 2025): FCA settlement, no admission, kickbacks for referrals, relators received $1.5M Creative Hospice $9.2M Primero / Beltran (Apr 2024): 33 months each, used nominees, sham hospice in Las Vegas Primero (Las Vegas) $7.1M Source: DOJ press releases, CA AG press release, FraudGraph CourtListener docket data  ·  Hover bars for detail

Cross-program signals visible in FraudGraph

The pattern most visible from any single dataset is "hospices clustering in California." The pattern most visible only when you cross several federal datasets is something more useful: the same operators appearing across multiple federal programs, with the kind of frequency that distinguishes opportunistic fraud from systemic operations.

Hospice + PPP overlap. FraudGraph's PPP loan table shows that across CA, NV, AZ, and TX, businesses registered under NAICS code 621610 (Home Health Care Services, the parent category for hospice) received 12,049 PPP loans totaling $1.69 billion — roughly 96% of which was forgiven. That figure includes many legitimate operators. But it also includes specific entities now in federal hospice fraud cases: a defendant in a Southern California hospice prosecution, Gayk Akhsharumov, was charged with separately using a defunct hospice company (San Gabriel Hospice) to fraudulently obtain a COVID-19 PPP relief loan in April 2020. The hospice fraud and the PPP fraud were the same set of facts, processed by two different federal benefits programs.

The hospice + home health + DME + lab cluster. FinCEN's March 2026 healthcare-fraud advisory describes the modal sophisticated scheme as a multi-entity ring, with nominee/straw owners running a hospice, a home-health agency, a DME supplier, and a clinical lab simultaneously, billing Medicare and Medi-Cal across the stack. The Petros Fichidzhyan case ran hospice plus home health out of the same network. The Sophia Shaklian case ran hospice plus diagnostic testing out of the same network, including $6 million laundered through gold bars. The "Operation Gold Rush" DME ring referenced by FinCEN had ~$41 million flowing through schemed DME companies in the same way. The cross-program structure is the operating model, not the exception.

Excluded individuals resurfacing. FraudGraph's copy of the HHS-OIG List of Excluded Individuals/Entities (LEIE) shows the hospice-specific case: an entity called We Care Hospice Services LLC in Sherman Oaks was excluded in December 2010 under section 1128(b)(8) of the Social Security Act. The Nita Palma case is the more troubling pattern — an excluded individual operating through family members, then through three additional hospices opened during the period she was already incarcerated. The 36-month rule, the new hospice survey requirements, and the suspended Special Focus Program were all designed to stop this exact behavior. So far, none of them has.

What to watch in 2026

The federal response is finally shifting from study to action, but the policy choices over the next twelve months will shape whether this becomes a genuine inflection point or another in a series of regulatory false starts.

First, watch the moratorium question. CMS has used its 42 CFR 424.570 enrollment-moratorium authority for home health agencies and DMEPOS suppliers, but never for hospices nationwide. The current regime is sub-regulatory: a "Provisional Period of Enhanced Oversight" (PPEO) imposed in California, Nevada, Arizona, and Texas in July 2023 and quietly extended to Georgia and Ohio. The Hospice CARE Act, reintroduced March 2026 by Senator Mark Warner and Representative Linda Sánchez, would legislate a five-year national moratorium with community-need exceptions. The state hospice associations are split: legitimate operators in underserved areas worry that a blanket freeze will harm patient access; everyone else seems to want it.

Second, watch the Special Focus Program restart and the HOPE assessment tool. CMS launched the SFP in December 2024, then suspended it in February 2025 to "further evaluate" the methodology after the initial cohort included 15 hospices with no condition-level deficiencies. The HOPE (Hospice Outcomes & Patient Evaluation) tool launches October 2025 and will give CMS standardized patient-level outcome data for the first time — the data that would make algorithmic outlier detection possible at scale.

Third, watch the qui tam pipeline. The Gentiva, Elara Caring, and Creative Hospice settlements were all resolutions of whistleblower lawsuits filed by former employees of for-profit hospice operators. The Department of Justice's $2.9 billion in FCA recoveries in FY 2024 included a substantial hospice contribution. California has revoked roughly 280 hospice licenses to date and reportedly has 300 more under investigation. The DOJ Healthcare Fraud Strike Force's June 2025 takedown charged 324 defendants and alleged $14.6 billion in fraud, with hospice cases featured prominently. The case pipeline is real.

The bottom line: Medicare hospice spending grew 119% between 2010 and 2024. Most of the growth was the for-profit segment. Most of the for-profit growth concentrated in four counties — Los Angeles, Riverside-San Bernardino, Clark, and Maricopa — that together account for 28% of every hospice in the country. The OIG warned about it in 2018, the California State Auditor exposed it in 2022, the DOJ has steadily escalated enforcement, and CMS has imposed enhanced oversight in the worst-affected states. In 2026, for the first time, there is bipartisan congressional appetite for a national moratorium and structural reform. Whether the political moment translates into durable rulemaking, or evaporates the way the skin substitute Local Coverage Determinations evaporated, is the question worth watching.
California Medicare Hospice Spending: Actual vs. Projected (FraudGraph data) $0B $1.5B $3B $4.5B $6B $7.5B 2018 2019 2020 2021 2022 2023 2024 2025* 2018: $2.50B (CA Medicare hospice payments, FraudGraph) 2019: $2.78B 2020: $3.12B 2021: $3.48B 2022: $3.50B (state moratorium effective Jan 2022) 2023: $3.81B (CMS PPEO begins July 2023) Projected without moratorium (extrapolated trend): ~$5.7B in 2025 If unchecked: ~$5.7B State moratorium (2022) CMS PPEO (Jul 2023) CA Medicare hospice payments (FraudGraph) Pre-moratorium trend extrapolation