Carrefour Associates LLC (operating as Crossroads Hospice)

Dayton, OH 2012--2014 Hospice
DOJ HHS-OIG Medicare Medicaid Fraud False Claims Act Hospice Ineligibility
Penalty
$5.5 million

Outcome

Carrefour Associates LLC, operating as Crossroads Hospice in Ohio and Tennessee, paid $5.5 million to resolve False Claims Act allegations that it billed Medicare for hospice care provided to patients with a diagnosis of dementia or Alzheimer's disease who were not terminally ill for at least a portion of the more than three years some patients received care.

Details

Crossroads Hospice (Carrefour Associates LLC) — Dementia Patient Hospice Overbilling in Ohio and Tennessee (2021)

Outcome: Carrefour Associates LLC, operating as Crossroads Hospice at locations in Ohio and Tennessee, paid $5.5 million to resolve False Claims Act allegations that it billed Medicare for hospice services provided to patients diagnosed with dementia or Alzheimer's disease who were not terminally ill for at least a portion of the period during which they received hospice care.

Crossroads Hospice operated hospice locations in Ohio (including Dayton) and Tennessee. The settlement, announced November 23, 2021, resolved allegations concerning conduct from January 1, 2012 to December 31, 2014.

The government alleged that during this three-year period Crossroads Hospice billed Medicare for hospice care for patients whose primary diagnosis was dementia or Alzheimer's disease, when the medical records for those patients did not support a terminal prognosis — specifically, a life expectancy of six months or less if the disease were to run its normal course. Medicare's hospice benefit is predicated on terminal prognosis, not on the nature of the diagnosis alone; dementia and Alzheimer's disease are recognized as hospice-eligible diagnoses but only when the disease progression has reached the advanced stage consistent with the six-month prognosis standard.

The conduct included patients who received hospice services for more than three years — significantly exceeding the six-month prognosis window — without being discharged or having the hospice election rescinded, suggesting that clinical reassessment of continued eligibility was not being adequately performed or documented at required recertification intervals.

The case was brought by four whistleblowers: Leanne Malone, Jackie Burns, and Angela Heck (former Crossroads Hospice employees), and Dr. David Weber (a home health physician in Tennessee). The whistleblowers in the Malone action received approximately $1,045,000. The settlement was coordinated by the U.S. Attorney's Office for the Western District of Tennessee and HHS-OIG.

Primary Source: Crossroads Hospice Agrees to Pay $5.5 Million to Settle False Claims Act Liability — DOJ Western District of Tennessee

How Crucible Prevents This

Crucible hospice eligibility controls specific to dementia and Alzheimer's diagnoses — conditions with characteristically slow and unpredictable decline trajectories — would require supporting clinical documentation of functional decline using validated scales (e.g., FAST, PPS) at each certification interval. Patients with non-cancer diagnoses who have been on hospice service for more than two years without documented decline would trigger mandatory clinical eligibility review and a compliance escalation prior to recertification. An extended-stay monitoring module would surface patients with dementia or Alzheimer's diagnoses and long lengths of stay as a targeted compliance risk category.

Source: Crossroads Hospice Agrees to Pay $5.5 Million to Settle False Claims Act Liability — DOJ Western District of Tennessee

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