Due Diligence Guide · Hospice & Palliative Care

Acquiring a Hospice Agency? Know What to Look for Before You Sign.

From Medicare cap exposure to referral source concentration, this guide covers every critical due diligence item for hospice and palliative care acquisitions.

Find Hospice & Palliative Care Acquisition Targets

Hospice acquisitions carry unique regulatory, clinical, and billing risks that standard business due diligence frameworks miss entirely. Medicare certification, annual cap calculations, OIG scrutiny, and referral anti-kickback compliance require specialized review before closing any deal in the $1M–$5M revenue range.

Hospice & Palliative Care Due Diligence Phases

01

Financial & Billing Review

Validate reported revenue, normalize EBITDA, and quantify Medicare overpayment and cap exposure hidden in historical cost reports.

Medicare Cost Report & Cap Analysiscritical

Review the last three Medicare cost reports and calculate current cap position. Approaching or exceeding the annual cap materially limits future revenue and signals potential billing compliance risk.

EBITDA Normalizationcritical

Adjust for owner compensation, related-party rent, personal expenses, and one-time costs. Hospice EBITDA margins of 20–30% are achievable but frequently obscured in owner-operated agencies.

Payer Mix & ADC Trend Analysisimportant

Analyze average daily census trends, payer mix, and live discharge rates over 24 months. Declining ADC or rising live discharges can indicate eligibility documentation problems or referral instability.

02

Regulatory & Compliance Review

Assess CMS certification status, survey deficiency history, and OIG exposure before assuming any liability tied to prior billing practices.

CMS Survey & Deficiency Historycritical

Pull all state survey reports and condition-level deficiency findings from the last three years. Active enforcement actions or unresolved plans of correction are deal-stopping red flags.

OIG & RAC Audit Exposurecritical

Request documentation of any OIG investigations, RAC audits, or Medicare recoupment demands. Undisclosed overpayment liabilities routinely surface post-close and can exceed hundreds of thousands of dollars.

Anti-Kickback Statute Compliance for Referralsimportant

Review all referral source agreements, marketing contracts, and medical director arrangements for AKS safe harbor compliance. Non-compliant referral relationships create federal liability that transfers with the business.

03

Operational & Clinical Assessment

Evaluate census quality, staff stability, and the strength of referral relationships that determine post-acquisition revenue sustainability.

Clinical Staff Licensure & Retention Riskcritical

Verify active licensure for all RNs, social workers, and the Director of Nursing. Identify key personnel flight risk, as clinical staff departures directly impact census capacity and Medicare compliance.

Referral Source Concentrationimportant

Map admissions by referral source for the prior 24 months. Any single hospital, SNF, or physician practice exceeding 20% of admissions represents significant revenue concentration risk post-close.

QAPI Documentation & IDT Recordsstandard

Review Quality Assurance and Performance Improvement meeting minutes and interdisciplinary team documentation. Gaps signal compliance weakness and increase post-close survey deficiency risk.

Hospice & Palliative Care-Specific Due Diligence Items

  • Confirm Medicare provider agreement is in good standing and model the CHOW timeline, which typically takes 90–180 days and requires CMS approval before billing can resume under new ownership.
  • Verify the agency is not approaching the Medicare hospice aggregate cap; agencies billing above 97% of cap limit face automatic payment withholding and potential recoupment demands.
  • Request length-of-stay statistics segmented by diagnosis; unusually long stays in non-cancer diagnoses can attract OIG scrutiny and indicate eligibility documentation deficiencies.
  • Assess medical director agreements for fair market value compensation documentation, as below- or above-market arrangements with referring physicians create anti-kickback statute exposure.
  • Evaluate EMR system compatibility with your platform, as hospice-specific systems like Netsmart or Brightree contain census, billing, and compliance records critical to post-close operations.

Frequently Asked Questions

What is the biggest hidden risk in a hospice acquisition?

Undisclosed Medicare overpayment liability and cap exposure. These often don't appear in standard financials but can result in six-figure recoupment demands surfacing months after closing.

How do hospice businesses typically get valued in the lower middle market?

Medicare-certified hospices with clean compliance records and stable ADC typically trade at 4–7x EBITDA, with higher multiples for agencies with diversified referrals and strong clinical leadership in place.

Can I use an SBA loan to acquire a hospice agency?

Yes. SBA 7(a) loans are commonly used for hospice acquisitions. Lenders will scrutinize Medicare certification status, compliance history, and normalized cash flow before approving healthcare service business loans.

How long does the Medicare change of ownership process take?

The CMS CHOW process for hospice typically takes 90–180 days. Buyers cannot bill Medicare under the new ownership until CMS approves the novation, making deal structure and timing critical.

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