Shanna Western still remembers seeing her grandfather waving both hands in unison through a hospital window. He called it his “twin wave,” a greeting and a goodbye to Western and her twin sister.
In the 1980s, hospitals generally discouraged children from visiting patients in the hospital rooms. Her grandfather died that night. Western never got the chance to say goodbye in person.
Ever since then, Western knew she wanted to help families navigate end-of-life care with more support and dignity. She has worked as a hospice nurse for 20 years in Southwest Virginia.
This spring, she came within weeks of opening Solace Hospice of Southwest Virginia, an independent nonprofit hospice based in Wytheville.
She secured a state license, hired staff, rented office space and overall invested more than $100,000 of her own money and community donations.
Then her efforts came to an abrupt stop.
On May 13, the federal Centers for Medicare and Medicaid Services announced a six-month nationwide moratorium on new Medicare enrollments for hospice and home health agencies. The policy immediately blocked new providers from joining Medicare, effectively preventing Western’s hospice from opening.
The moratorium is part of a federal effort to combat Medicare fraud. A task force led by Vice President JD Vance coordinated with the agency on the initiative, which CMS says will allow investigators to intensify fraud enforcement and prevent bad actors from shifting operations between states.
“I feel like I spent the past year putting this all together and getting ready to serve the patients. And then at the end of the week, I’m not going to have anything left to show for it but a busted dream,” Western said.
The timing could not have been worse. Enrolling in Medicare was one of the last steps before Western could start seeing patients.
Without Medicare certification, Western cannot enroll with Virginia Medicaid and is unlikely to secure contracts with most commercial insurers. Meanwhile, her monthly expenses, including rent and insurance, total about $10,000.
Last Friday, Solace Hospice’s board voted to wind down operations before the organization ever saw its first patient. For now, the nonprofit is minimizing its expenses as much as possible. It will continue fundraising efforts through the moratorium, and if possible, Western will reapply for Medicare enrollment when the freeze ends.
“As a nonprofit hospice, we were established with the expectation that we would never bill patients or families directly for end-of-life care. While our policies could theoretically be revised, doing so would be contrary to the mission and values on which Solace was founded,” Western said.
CMS guidance indicated that applications postmarked on May 12 could still be considered through an appeals process. Western said there is no point: Her documents were mailed on May 13, the day of the moratorium, and received by CMS on May 18.
Hospice fraud concerns reignited by California case
Federal scrutiny of hospice programs intensified this spring after prosecutors charged 21 people involved in a hospice fraud scheme that allegedly defrauded California’s Medicare program of $267 million, according to a press release from the state attorney general’s office.
The defendants purchased personal identifying information for non-California residents on the dark web and used those identities to enroll in the state’s Medicaid system. The group allegedly acquired 14 hospice companies through straw owners and billed for hospice services that were never provided.
Not everyone supports the national freeze as a solution to Medicare fraud.
Community Health Accreditation Partner, or CHAP, a national hospice accrediting organization, criticized the moratorium during a May 15 webinar for providers.
“CHAP, along with many state and national associations and providers, opposes the nationwide moratorium for all new providers as it risks penalizing legitimate providers operating in good faith and also limits beneficiary access and choice without addressing and targeting the existing fraudulent actors,” a CHAP spokesperson said during the webinar.
Sen. Tim Kaine, D-Va., said he is hopeful that the state will support impacted providers.
“For years, we’ve seen issues with billing and the quality of care at hospice and home health agencies,” he said in a statement. “While I support reforms to ensure we prevent fraud, we must also ensure Virginians have access to the care they need. I encourage CMS to work with state and local partners to ensure that Virginians aren’t impacted by this moratorium.”
Rep. Morgan Griffith, R-Salem, acknowledged the moratorium’s impact on providers in Virginia.
“I regret if this has caused any legitimate new hospice and home health agency a problem. But with multiple billions of dollars in fraud attributable to false and fraudulent Medicare agency claims, a six-month delay is prudent,” Griffith said in an email.
Sen. Mark Warner, D-Va., pointed to legislation he introduced this spring, the Hospice Care Accountability, Reform, and Enforcement (Hospice CARE) Act. The proposal would establish a five-year nationwide moratorium on new hospice enrollment in Medicare while allowing exceptions in areas with demonstrated unmet need.
“I am deeply concerned that this administration wants the appearance of fighting fraud because it sounds good. A moratorium is a tool that needs to be considered seriously and should be used carefully. I am hopeful that this six-month moratorium is plenty of time for CMS to determine what states and the federal government should do to prevent fraud,” Warner said in an emailed statement to Cardinal News.
“If CMS wants to extend the moratorium, the administration needs to come to Congress and work with us on policies, like the ones in my bill, that would give them the flexibilities they need to exempt new hospices that do not pose a risk of fraud and are ready to provide high-quality hospice care in our communities.”
A year of work halted overnight
Western began building the home hospice business in July 2025 using her personal savings and retirement funds. As costs mounted, she sought community donations, secured a grant from the Wythe-Bland Foundation and opened a line of credit.
She organized bake sales, yard sales and online fundraisers to help finance the project.
Eventually, she raised enough money to rent office space and hire staff. Several hospice nurses who had worked with Western at other hospice facilities in the area agreed to join the organization. She also hired a grief counselor to support families through bereavement.
The state issued Solace Hospice a license on April 28.
Soon afterward, Western’s team gathered the money for the $750 Medicare enrollment fee and submitted its application. The application was postmarked May 13 — the day the moratorium took effect. She said she did not receive any advance warning. Instead, she found out when a friend, who also works in hospice, sent her a link to the CMS news release.
The Virginia Department of Medical Assistance Services learned about the moratorium at the same time as the public, Kendra Keith, public relations and communications manager for the department, said in an email Monday.
Western estimated it cost more than $100,000 to bring the organization to that point.
She said the freeze disproportionately affects small, independent providers that lack the financial resources of larger corporations, which can draw on existing profits when opening a new branch.
The moratorium also limits patient choice in rural communities where hospice options are already scarce, she said.
According to Medicare’s Care Compare tool, Wytheville currently has two hospice providers, both owned by for-profit companies.
Solace Hospice was also licensed by the state to provide pediatric hospice care, a specialized service Western said is difficult to access in Southwest Virginia.
Before Solace Hospice received its state license, Western said she learned of a young girl in Bland County who needed hospice services. The nearest provider was about 90 minutes away.
“This is just a blanket solution [to Medicare fraud], which is not really a solution for the problem at hand because it doesn’t give legitimate providers the opportunity to provide care. And then it also takes away patient choice because some patients may want nonprofit hospice or something independent,” Western said.
