San Gabriel and Broadway Hospice: The Biller Behind the False Ownership Forms

In the San Gabriel and Broadway hospice case, Medicare paid $3,180,677 to San Gabriel after a biller and consultant submitted false enrollment forms concealing its owners and managers, according to the Justice Department’s account. The paperwork named someone else. Taxpayers paid a business whose real owners were hidden from Medicare. An employee who knew who actually ran the business could see what Medicare could not.

A Sole Owner on Paper

According to the Justice Department, the biller submitted Medicare enrollment forms for San Gabriel Hospice and Palliative Care Inc. that falsely identified a straw owner as the sole owner and manager. The forms concealed the people who actually owned and managed the hospice.

A straw owner supplies a name for the paperwork while someone else retains the interest or control. In this form of hospice fraud, the false statement concerns the business asking Medicare to pay it. Concealed ownership sits upstream of the patient chart and the bill.

The department’s later account of the two California hospices identified a manager and beneficial owner of both San Gabriel and Broadway Hospice Inc. It described the other participant as that operator’s biller and consultant. The enrollment forms attributed to the biller concerned San Gabriel.

The Owner, the Recruiters, and the Relief Money

The wider Medicare scheme ran from around January 2018 through May 2021. The Justice Department described approximately $9 million taken from Medicare through the owner’s two hospices. It attributed concealed ownership, nominee owners and kickbacks to patient recruiters to the operator.

The referral payments matter alongside the enrollment forms. One brought patients into the business. The other concealed who stood behind the business receiving Medicare’s payments.

The Justice Department also described the owner obtaining pandemic-relief funds through San Gabriel after it had ceased operating. The company had stopped operating, but its name and account still received public money.

Why the Billing Number Was Valuable

Medicare pays routine hospice care by the enrolled day, including days without a visit. The hospice assumes responsibility for care related to the terminal illness, including nursing, drugs, equipment and supplies.

The payment incentive helps explain why control of a hospice is valuable. The HHS Office of Inspector General’s 2015 study, Medicare Hospices Have Financial Incentives to Provide Care in Assisted Living Facilities, examined Medicare hospice claims through 2012 and found longer stays and higher payments for beneficiaries in assisted living than in other settings. It stated the broader incentive plainly:

The report also found that assisted-living beneficiaries often had diagnoses requiring less complex care. That matters to the daily-payment incentive: a longer stay can bring in more money without a matching increase in the work needed from the hospice.

For an insider examining hospice billing, the enrolled days and the care delivered belong beside the ownership and payment records.

When Referral Pay Reaches the Claim

Tapestry Hospice agreed to a $1.4 million settlement in a separate civil case over alleged referral payments. The Justice Department alleged that medical directors received monthly stipends and a signing bonus, with compensation rising when referrals increased and falling when they did not.

That parallel shows why the compensation arrangement belongs in a hospice fraud inquiry. The title on a contract can describe medical work while the payment follows patient volume. An insider who knows how compensation was set can explain what the business was buying.

A former Tapestry employee brought the whistleblower case and received a share of the recovery. The civil case put the payment arrangement before the government through someone who had worked inside the business.

Why Medicare Tightened Hospice Enrollment

Hospice administrators and medical directors must be reported as managing employees on Form CMS-855A, the Medicare enrollment application for institutional providers. CMS explained in its May 2026 enrollment notice that this lets the agency identify people serving in those roles at multiple hospices.

The agency described numerous hospices operating from single buildings or concentrated in small areas of Los Angeles County. A business name and an office address tell only part of that story. The managing-employee disclosures let CMS connect different providers through the people running them. For a biller or administrator, that is a concrete part of the enrollment paperwork, alongside the ownership representation at the center of the San Gabriel case.

CMS also explained why it extended the 36-month ownership rule to hospices. Quickly selling an enrolled business could let its buyer bypass the survey or accreditation that would otherwise examine the provider under its new ownership. The agency described operators whose principal motivation was selling the business rather than furnishing good patient care. The rule brings the new owner and hospice back under scrutiny.

A nationwide six-month moratorium on new Medicare hospice enrollment took effect May 13, 2026.

What Evidence Is Needed to Prove Fraud?

For concealed-ownership allegations, the useful evidence connects the enrollment representation to the actual decision-makers and the money. We examine applications and amendments alongside instructions about their contents, ownership records, claims and payment reports.

Billers see the provider identity, claim dates and care levels. Finance and compliance staff may see compensation, internal warnings and management’s response. We work with insiders to connect those views to a potential whistleblower case.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

You Know Who Gave the Instructions

If the owner named to Medicare differs from the person directing your hospice’s billing, speak to one of our whistleblower experts about who really ran the hospice. We work with you to build your strongest hospice whistleblower case around the false forms, the decisions and the payments. We bring in hospice fraud whistleblower lawyers who understand provider enrollment and stay beside you through the case.