Public Data POC · 2026-04-27 · Hospice 2023

$165,468,543 flagged in 8 seconds. From public Medicare data.

JIL's Adversarial Verification Engine ran a single pass over the public CMS Hospice All Owners file and 2023 utilization data. 15 owner networks surfaced as anomalous candidates - each billing 71% above the national median per stay. None of them are currently DOJ-prosecuted. The same engine runs against an MCO's settlement ledger under BAA in Tier 2.

$165,468,543
Combined 2023 Medicare payment
$68,861,457
Overage vs national median
15
Owner networks flagged
< 8 sec
Single-pass runtime
Section 01 · Methodology

Real public data. Two CSVs. Open citations.

Every signal in this POC comes from CMS public data files that anyone can download. No subscription. No customer engagement data. No PHI. Same engine the MCO product uses; just running with the public-data subset of capabilities.

Runtime: < 8 seconds (single-pass on a CPX62-class node). National benchmarks: median per stay $14,677, p75 $18,436, p90 $23,036. Cohort: 4,912 Medicare-enrolled hospices, 22,596 unique individual owners indexed.
Section 02 · AVE Pipeline (POC scope)

All eight AVE models. The cards in Section 03 mark which ones fired.

AVE has eight investigation models (numbered 1-8 below, matching the design page). Six run today on public data. Two need customer-side data: bank fingerprinting (3) requires wire records under BAA and is Tier 2 only; premise / volume (4, 6) reach full strength once USPS / Street View AI / ATTOM credentials are wired. Each candidate card in Section 03 carries a row of model chips - the gold-bordered chips are anchor models for that finding, the gray chips are corroborating signals.

01

Claim Patterns

Statistical outliers vs national + state cohorts on per-stay payment, per-bene payment, days-per-stay.
Live
02

UBO Resolution

Direct from CMS Owners file. Cross-entity ownership graph. Augmentable with OpenCorporates + state SOS.
Live
03

Bank Fingerprinting

HMAC of routing+account at ingest. Tier 2 only - requires customer wire records under BAA.
Tier 2 only
04

Premise Classification

NPPES address + cross-state distribution today. USPS API + Street View AI on signup.
Partial
05

Business-Premise Compat

40-row matrix (hospice in retail strip, DME at UPS Store, daycare-therapy mismatch, etc.) seeded from AVE design.
Live
06

Volume Capacity

Claim volume from CMS PUF + per-network throughput math. ATTOM API on signup for square-footage capacity.
Partial
07

Exclusion Lists

OIG LEIE + SAM + OFAC + OpenSanctions cross-reference. None of the 12 candidates below match a current exclusion - which is itself the signal: pattern visible, no enforcement yet.
Live
08

Network Detection

Three of four overlay graphs (UBO, address co-location, premise mismatch). Bank graph adds at Tier 2. Cross-MCO / multi-state networks are an explicit network-detection signature.
Live
Section 03 · Findings · Owner networks

Top 12 flagged candidates from public CMS data

Each candidate is an individual listed on CMS as 5%+ owner of multiple Medicare-enrolled hospices, where the network's 2023 average payment per beneficiary stay materially exceeds the national median. Anomalous pattern, not adjudicated finding. AVE Tier 2 investigation determines whether the pattern reflects a legitimate operating model or a fraud network. Each card carries an "AVE models on this finding" row - the gold-bordered chips are anchor models, the gray chips are corroborating signals.

1
Claim Patterns
Anchor on every card
Fires on 12 of 12
2
UBO Resolution
Anchor on every card
Fires on 12 of 12
3
Bank Fingerprinting
Tier 2 only
Activates under BAA
4
Premise Classification
Partial / multi-state
Fires on multi-state cards
5
Business-Premise Compat
Live
Hospice-as-service-line check
6
Volume Capacity
Partial
Fires on high-density networks
7
Exclusion Lists
Live, 0 hits
No current OIG-LEIE match
8
Network Detection
Anchor on every card
Fires on 12 of 12
Legal posture. The names and CMS data below are extracted verbatim from the CMS Hospice All Owners file (publicly downloadable, refreshed quarterly). This page presents factual public-record data and statistical comparisons. No allegation of fraud is made against any named individual or entity. AVE's role at Tier 1 is to surface candidates worth Tier 2 investigation. Tier 2 determines disposition.
#01
+111% vs median

KSENIA OGANNI

Listed as 5%+ owner on 6 Medicare-enrolled hospices (2 matched in 2023 utilization data) across CA, 2 unique cities.

$2,135,8332023 Medicare payment
69Beneficiary stays
$30,954Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • La Hospice Center Inc Toluca Lake, CA 91602 $1,376,038 / 32 stays / $43,001 per stay
  • I Know Hospice Inc Tarzana, CA 91356 $759,795 / 37 stays / $20,535 per stay
#02
+87% vs median

NICOLA AZAR

Listed as 5%+ owner on 7 Medicare-enrolled hospices (3 matched in 2023 utilization data) across CA, 2 unique cities.

$3,504,0342023 Medicare payment
128Beneficiary stays
$27,375Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Dhs Hospice Care N Hollywood, CA 91602 $2,848,165 / 103 stays / $27,652 per stay
  • Best Quality Hospice And Palliative Care Inc Van Nuys, CA 91401 $458,948 / 14 stays / $32,782 per stay
  • Angels Of Valley Hospice Care Inc Van Nuys, CA 91401 $196,921 / 11 stays / $17,901 per stay
#03
+85% vs median

LOUIS FLORES

Listed as 5%+ owner on 7 Medicare-enrolled hospices (3 matched in 2023 utilization data) across CA, 3 unique cities.

$3,955,1322023 Medicare payment
146Beneficiary stays
$27,089Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Dhs Hospice Care N Hollywood, CA 91602 $2,848,165 / 103 stays / $27,652 per stay
  • Lucky Palliative Services Incorporated Canoga Park, CA 91303 $648,019 / 29 stays / $22,345 per stay
  • Best Quality Hospice And Palliative Care Inc Van Nuys, CA 91401 $458,948 / 14 stays / $32,782 per stay
#04
+82% vs median

KRISTINE VARDANYAN

Listed as 5%+ owner on 4 Medicare-enrolled hospices (3 matched in 2023 utilization data) across CA, 3 unique cities.

$5,392,9172023 Medicare payment
202Beneficiary stays
$26,697Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Healing Halo Hospice And Palliative Care Inc Agoura Hills, CA 91301 $2,962,077 / 97 stays / $30,536 per stay
  • Glendale Hospice Inc North Hollywood, CA 91605 $1,380,245 / 44 stays / $31,369 per stay
  • Elegant Hospice Care Woodland Hills, CA 91364 $1,050,595 / 61 stays / $17,222 per stay
#05
+78% vs median

SANDHYA BHALLA-REGEV

Listed as 5%+ owner on 3 Medicare-enrolled hospices (3 matched in 2023 utilization data) across CA, 1 unique cities.

$90,439,9772023 Medicare payment
3,459Beneficiary stays
$26,146Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Vitas Healthcare Corporation Of California Sacramento, CA 95833 $30,146,659 / 1,153 stays / $26,146 per stay
  • Vitas Healthcare Corporation Of California Sacramento, CA 95833 $30,146,659 / 1,153 stays / $26,146 per stay
  • Vitas Healthcare Corporation Of California Sacramento, CA 95833 $30,146,659 / 1,153 stays / $26,146 per stay
#06
+72% vs median

TRILOCHAN SINGH

Listed as 5%+ owner on 3 Medicare-enrolled hospices (2 matched in 2023 utilization data) across CA, 2 unique cities.

$8,345,3652023 Medicare payment
331Beneficiary stays
$25,212Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Care Must Hospice Inc San Jose, CA 95135 $7,069,648 / 276 stays / $25,614 per stay
  • Savior Hospice Care Inc Napa, CA 94559 $1,275,717 / 55 stays / $23,194 per stay
#07
+66% vs median

FARIBA JAVAHERIAN

Listed as 5%+ owner on 14 Medicare-enrolled hospices (5 matched in 2023 utilization data) across CA, 3 unique cities.

$6,787,6142023 Medicare payment
279Beneficiary stays
$24,328Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Throne Hospice Inc N Hollywood, CA 91601 $1,530,250 / 54 stays / $28,337 per stay
  • La Best Hospice Care Van Nuys, CA 91401 $1,440,887 / 55 stays / $26,197 per stay
  • Ts Compassion Hospice & Palliative Care Inc Sherman Oaks, CA 91411 $1,403,765 / 78 stays / $17,996 per stay
  • Edem Hospice Inc Van Nuys, CA 91405 $1,389,063 / 55 stays / $25,255 per stay
#08
+61% vs median

SIEGHART PONHOLD

Listed as 5%+ owner on 9 Medicare-enrolled hospices (3 matched in 2023 utilization data) across CA, 3 unique cities.

$4,080,1472023 Medicare payment
173Beneficiary stays
$23,584Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Warm Care Hospice And Palliative Care Garden Grove, CA 92840 $1,750,770 / 73 stays / $23,983 per stay
  • Angel Storm Hospice Care Inc North Hollywood, CA 91601 $1,621,205 / 67 stays / $24,197 per stay
  • Trustable Hospice Inc Van Nuys, CA 91401 $708,172 / 33 stays / $21,459 per stay
#09
+60% vs median

VIOLETA VICENSIO

Listed as 5%+ owner on 5 Medicare-enrolled hospices (3 matched in 2023 utilization data) across CA, 2 unique cities.

$2,987,6102023 Medicare payment
127Beneficiary stays
$23,524Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Smart Choice Hospice Inc Chatsworth, CA 91311 $1,184,611 / 51 stays / $23,227 per stay
  • Fellowship Hospice Services Inc Anaheim, CA 92801 $1,022,217 / 43 stays / $23,772 per stay
  • Devine Hospice Care Inc Chatsworth, CA 91311 $780,782 / 33 stays / $23,660 per stay
#10
+57% vs medianMulti-state

ALOK SAXENA

Listed as 5%+ owner on 8 Medicare-enrolled hospices (2 matched in 2023 utilization data) across CA / NV, 2 unique cities.

$3,714,7692023 Medicare payment
161Beneficiary stays
$23,073Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Comforting Hands Hospice Glendale, CA 91203 $1,958,719 / 96 stays / $20,403 per stay
  • Preferred Hospice Care Inc Las Vegas, NV 89117 $1,756,050 / 65 stays / $27,016 per stay
#11
+57% vs medianMulti-state

ABDUL KHAN

Listed as 5%+ owner on 9 Medicare-enrolled hospices (5 matched in 2023 utilization data) across CA / MI, 5 unique cities.

$13,247,5262023 Medicare payment
576Beneficiary stays
$22,999Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution4Premise Classification5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Americans Hospice Care Inc Saginaw, MI 48604 $5,251,955 / 240 stays / $21,883 per stay
  • All Americans Hospice Care Inc Flint, MI 48532 $4,615,482 / 219 stays / $21,075 per stay
  • La Hospice Services Inc Los Angeles, CA 90029 $1,362,044 / 36 stays / $37,834 per stay
  • Red Cross Hospice Inc Northridge, CA 91324 $1,222,404 / 50 stays / $24,448 per stay
#12
+55% vs median

VARDAN GEVORGYAN

Listed as 5%+ owner on 3 Medicare-enrolled hospices (2 matched in 2023 utilization data) across CA, 1 unique cities.

$2,044,2532023 Medicare payment
90Beneficiary stays
$22,713Avg per stay
AVE models on this finding
1Claim Patterns2UBO Resolution5Business-Premise Compat6Volume Capacity8Network Detection
Top hospices in this network
  • Pure Soul Hospice Inc North Hollywood, CA 91601 $1,929,933 / 70 stays / $27,570 per stay
  • Infinite Life Inc North Hollywood, CA 91601 $114,320 / 20 stays / $5,716 per stay
Section 04 · Why it matters

Detection at scale beyond DOJ's investigative bandwidth.

DOJ FCA recoveries hit a record $6,800,000,000 in FY 2025, with 1,297 qui tam filings - the highest in U.S. history. None of the 15 candidates above appear in current DOJ healthcare-fraud press releases. They billed Medicare $165,468,543 in 2023 alone - 71% above what the national-median rate predicts for the same stay count.

Three things this POC demonstrates:

  1. The data exists publicly. CMS publishes ownership and utilization quarterly. Anyone can download it. Few do anything with it at this scale.
  2. The detection is fast. 8 seconds on a single CPX62-class node. AVE's eight-capability pipeline orchestrates from this baseline.
  3. The reach is broad. Hospice is one slice. The same engine runs on DME, physician services, behavioral health, home health, dialysis. Same architecture, different cohorts.
The flip: if AVE can flag $68,861,457 in anomalous billing on public data alone in 8 seconds, the question for any MCO or state Medicaid program is not "do we have an AVE engagement?" - it is "are we already on someone's qui tam target list?"

Detect early. Prove it. Stay safe.

This POC ran on public data. The full Tier 2 stack (bank fingerprinting, FinCEN BOI, Street View AI, ATTOM premise records) ships with the customer engagement under BAA + GLBA + per-engagement legal-basis authorization. CREB output is FRE 902(14)-anchored and reproducible in discovery.

Schedule a discovery call Walk the public AVE demo See the 20-slide MCO deck Read the AVE design