The scope of Qlarant's audit targets remains partially opaque. CMS has established Provisional Periods of Enhanced Oversight (PPEO) in fraud hotspots, but the specific criteria triggering individual provider audits and the volume of providers currently under review have not been disclosed. The House investigation's evidentiary findings and timeline for conclusions are also unclear.
Hospice operators should treat this enforcement posture as structural, not cyclical. The combination of congressional pressure, predictive auditing, and state-level licensing moratoria in California signals a shift from industry growth to compliance gatekeeping. Providers should audit their own eligibility documentation, length-of-stay patterns, and discharge practices against UPIC standards now. Those operating in PPEO states face heightened scrutiny; those with extended-stay or high-discharge-volume profiles should expect contact. Counsel should review billing practices and documentation protocols before audits arrive, not after.