With the ever-changing nature of the Medicare billing regulations, and with the complex web of health care laws governing home health agencies and hospices, audit contractors and federal agencies (including the Centers for Medicare and Medicaid Services (CMS), the Drug Enforcement Administration (DEA), the Federal Bureau of Investigation (FBI), and the Office of Inspector General (OIG)) have a deep bag of tools for taking action against these businesses. While intent to commit fraud is a requirement to prove criminal culpability,