What $799 Million of Arizona Hospice Spending Looks Like in Public Data

A federal fraud bounty program had just been announced. I wanted to know how far a person could get with public Medicare data and no subpoena.

The answer after four datasets is that public records point at reporting failures with precision. They do not point at fraud. The gap between those two things is the whole story.

Before anything else. No person or company named in this post is accused of a crime. Every figure below comes from a public CMS file. A missing record in a public file means a record is missing from that file. It does not mean anyone did anything wrong.

The data

Four CMS sources are free and need no login.

Medicare Post-Acute Care Utilization gives annual totals per provider: beneficiaries, visits, days, and dollars. Provider enrollments list every CCN, its NPI, and its address, republished monthly. The All Owners files list who owns each provider. Cost reports hold each provider's own accounting.

I started with Arizona hospice because the state has a dense market and a recent enrollment wave.

What the utilization data showed

267 Arizona hospices hold a Medicare CCN. 207 of them billed in 2024, for $798.9 million. Sixty CCNs sat dormant.

Among the 165 providers with at least 50 beneficiaries, the median stay was 90 days. The national median was 75.5. Median payment per beneficiary was $17,053 against $15,236 nationally.

Home health ran the other way. 127 Arizona agencies billed in 2024. The state came in below national on cost per episode ($1,841 vs $1,934) and cost per beneficiary ($4,495 vs $5,957). A state-level claim about home health would have been wrong. The variance sat in individual providers.

The address

Sorting enrollment addresses by CCN count produced 61 Arizona addresses with two or more Medicare providers. The largest held 24.

4150 W Peoria Ave in Phoenix carried 23 hospices and one home health agency across 24 suites. Together they billed $9,937,629 across 793 beneficiaries in 2024. Thirteen of the 24 CCNs had no 2024 billing at all.

Eleven of those hospices sat in lettered sub-suites of one 1,650 square foot basement unit, B116-A through B116-K. That comes from the building's own leasing plan.

What the cost reports said

Every Medicare hospice files an annual cost report. I pulled the HCRIS extract for 187 Arizona hospices with a usable filing.

Twelve of the 23 hospices at 4150 W Peoria have no cost report in the public extract for any fiscal year from 2015 through 2026. Statewide, 41 of 263 enrolled hospices have none.

Two that did file reported operating costs that cannot fund a hospice:

• Caring Hands Palliative and Hospice Care (031779) reported $136,587 of operating expense against $300,962 of revenue for a full 12-month period. That is $65.95 per patient day across 2,071 days.
• Angel Loving Care Hospice (031763) reported $76,205 of expense against $537,088 of revenue for a 167-day period ending June 15, 2024. That is $27.54 per patient day.

Arizona's median runs near $180 to $200 per patient day. Both filings agree to the worksheets, so those are the numbers the providers reported.

The counterexample matters. One address I expected to look bad, 1837 S Mesa Dr, held a hospice and two home health agencies under a single Miami holding company. Their combined 2024 revenue was $6.16 million with a 10.8% margin. That is an ordinary post-acute operator, and the ownership flags on those entities describe history, not profit.

The exclusion list that does not join

The obvious next step is the OIG exclusion list, which names 84,093 people and entities barred from federal programs.

It cannot be joined to CMS ownership data. Only 8,743 of those records carry an NPI. The CMS owner files carry no NPI and no date of birth. The field that looks like an identifier is not one. Zero of 173,659 owner associate IDs pass the NPI check digit test.

Name matching produced 548 candidates, all common-name collisions. Reporting those as findings would have been wrong.

The exercise did expose something else. Home health and hospice face the same ownership reporting rule, in the same state, in the same two files. Every one of 140 Arizona home health enrollments has an owner row. Only 141 of 251 hospice enrollments do. At 4150 W Peoria, 20 of 23 hospices have none.

Twenty-three Arizona hospices billed Medicare in 2024 with no owner row in the public file, for $54,455,096 across 3,120 beneficiaries. Some of those are national chains that certainly disclose ownership somewhere, so the gap may sit in CMS publication rather than provider reporting. From public data alone, the two cannot be told apart.

NPPES gave the names

The Arizona Corporation Commission no longer serves an anonymous entity search. Every path redirects to a login page.

NPPES does not. It publishes the authorized official for every organizational NPI. Pulling all 896 Arizona hospice NPIs returned a named officer for ten of the eleven non-filers, all enumerated between February and December 2021.

Two people accounted for three of the eleven, and for twelve NPIs between them. One was authorized official for seven Arizona hospice NPIs, of which two ever obtained a CCN. The other held five, of which one did.

102 of the 896 NPIs list 85029, the ZIP code for 4150 W Peoria, as their location.

Three terminations

One hospice, Amadeo (031768), had an NPI that returned nothing from NPPES. The number passed the check digit test, so CMS had issued it. Querying eleven monthly enrollment snapshots placed the termination between April and July 2024.

Two neighbors had also left:

A hospice that leaves the program still owes a cost report for its final partial period. None of the three filed one.

What this is

The output is a list of public-document gaps. Missing cost reports, missing owner rows, missing final filings, and one ZIP code holding 11.4% of the state's hospice NPIs. Each is checkable by anyone with a browser.

What this is not

None of it is evidence of a crime. A missing cost report can be an unprocessed submission. A missing owner row can be a CMS publication gap. A deactivated NPI can be a business that closed. A provider that bills $300,000 on $136,000 of reported cost may simply have reported its costs badly.

Fraud requires a false claim. That lives in claims data, which is not public, and in patient records, which need a subpoena. Public data gets you to the twenty files worth reading first. It does not get you to a conclusion.

What I would pull next

Three sources would extend this without an account. Arizona Corporation Commission filings give officers and statutory agents, once an account exists. SAM.gov exclusions carry UEI and CAGE identifiers, so entities can be matched without name guessing. The CMS Deactivated NPI Report gives deactivation dates, and it is currently offline.

The full dataset and scripts are in the repo, and every number above can be reproduced from the public files cited.