Compassion Hospice self-disclosed to OIG and settled for $430,752 for paying Medical Director compensation that took into account physicians' volume or value of referrals to the hospice.

Compassion Hospice, Inc. (Beaumont, TX) — Referral-Based Medical Director Compensation

Outcome: Self-disclosed to OIG and settled for $430,752 for structuring Medical Director compensation for two physicians in a way that improperly tied payments to those physicians' referral volume or value.

Compassion Hospice, Inc., a hospice provider in Beaumont, Texas, violated Anti-Kickback provisions of the Civil Monetary Penalties Law by compensating two Medical Directors in a manner that "took into account the physicians' volume or value of referrals" to the hospice. Under the Anti-Kickback Statute, compensation to physicians who make referrals to a provider must be based on legitimate services rendered — it cannot be tied to referral volume or value.

Medical Director compensation is one of the most scrutinized areas of hospice compliance because the Medical Director's clinical certification of terminal illness is both a regulatory requirement and a potential referral-generating relationship. When a hospice pays its Medical Directors based on how many patients they refer or certify, it creates a financial incentive that corrupts both the clinical certification process and the integrity of the referral relationship.

Compassion Hospice voluntarily self-disclosed the conduct to OIG. The $430,752 settlement was recorded September 8, 2025.

Primary Source: Compassion Hospice Agreed to Pay $430,000 for Allegedly Violating the Civil Monetary Penalties Law by Paying Improper Remuneration in the Form of Referral Based Compensation