The Centers for Medicare & Medicaid Services (CMS) has announced a nationwide, six-month Medicare enrollment moratoria for new hospices and home health agencies. The moratoria became effective May 13, 2026, and are part of a broader CMS program-integrity initiative targeting fraud, waste, and abuse in the hospice and home health sectors. CMS described the action as a "data-driven" effort to prevent new high-risk providers from entering Medicare while the agency continues investigations and enforcement activity involving existing providers.
The moratoria apply nationwide, including all states, territories, and the District of Columbia. For both home health agencies (HHA) and hospices, the moratoria bar enrollment of new HHAs and hospices, as applicable, as well as HHA branches and HHA and hospice practice locations unless the applicable enrollment application was received before May 13, 2026.
Key Takeaways
The moratoria do not automatically terminate current Medicare enrollments, and CMS states that existing providers may continue furnishing services to Medicare beneficiaries. However, existing providers should not view the announcement as limited to new market entrants. The moratoria may affect expansion plans, pending enrollment applications, new branch or practice-location additions, and certain ownership transactions that require a new Medicare enrollment.
The moratoria are currently limited to Medicare enrollment. CMS is not requiring states at this time to impose parallel Medicaid or CHIP moratoria, but it is encouraging states to consider tailored moratoria for home health and hospice providers and is offering to consult with states and territories on Medicaid- and CHIP-based actions.
The initial moratoria will last six months, but CMS may extend them in six-month increments. CMS may also lift a moratorium earlier if specified circumstances occur, including where the relevant program-integrity concerns have abated or the moratorium is no longer needed.
Scope of the Moratoria
For HHAs, CMS has imposed a nationwide temporary moratorium on the enrollment of all new HHAs. CMS states that a non-exempt change in majority ownership, or CIMO, that requires the HHA to enroll as a new provider under 42 C.F.R. § 424.550(b) will be blocked during the moratorium because the resulting enrollment would be treated as an initial enrollment.
As with HHAs, CMS states that a hospice undergoing a non-exempt CIMO within the 36-month period applicable in 42 C.F.R. § 424.550(b) would be required to enroll as a brand new hospice and therefore would be prevented from re-enrolling during the moratorium.
Enrollment applications received by the applicable Medicare contractor before May 13, 2026, are not subject to the moratoria. Providers with pending applications should promptly confirm and preserve evidence of the date and time of Medicare Administrative Contractor (MAC) receipt, not merely the date of internal completion or submission preparation.
CMS's Rationale
CMS states that the moratoria are intended to "temporarily halt the influx of new providers" in two categories the agency views as high risk for fraud. During the moratoria, CMS says it will intensify targeted investigations, use advanced data analytics, and accelerate removal of hospice and HHA providers suspected of fraud. CMS also stated that a nationwide approach is intended to prevent operators from avoiding scrutiny by shifting across state lines.
CMS cited significant enforcement activity in announcing the moratoria, including the suspension of payments to 773 hospices and 23 HHAs suspected of fraud in Los Angeles alone, representing approximately $70 million in suspended funds. CMS also pointed to related program-integrity measures, including hospice site visits, heightened oversight of newly-enrolled hospice providers in certain states, enhanced enrollment screening for high-risk HHAs, and expanded pre- and post-claim review for HHA claims in selected states.
Practical Implications for Providers, Investors, and Lenders
The moratoria will have immediate consequences for de novo growth strategies in the hospice and home health sectors. New Medicare enrollment applications that were not received by the MAC before May 13, 2026, are likely to be denied. New branch and practice-location strategies should be reassessed, particularly where the business plan depends on Medicare certification or billing privileges during the six-month period.
M&A transactions require particular attention. Buyers, sellers, lenders, and investors should evaluate whether a proposed transaction will trigger a new Medicare enrollment, especially where the provider is within 36 months of initial enrollment or a prior CIMO. A transaction that appears commercially viable under state licensure rules may still be impracticable if it requires a new Medicare enrollment during a moratorium.
Existing providers should also expect increased scrutiny. Although the moratoria do not bar currently enrolled providers from continuing operations, CMS has made clear that the enrollment freeze is only one part of a broader enforcement effort. Hospice and HHA operators should review documentation supporting Medicare eligibility, medical necessity, physician certification, plans of care, referral-source arrangements, marketing practices, ownership disclosures, and practice-location information.
Limited Appeal Rights
CMS's decision to impose enrollment moratoria is not subject to judicial review. A provider or supplier denied enrollment because of a moratoria may use existing administrative appeal procedures, but the scope of such an appeal is limited to whether the applicable moratorium applies to that provider or supplier. If an application fee was required and the application is denied because of the moratorium, CMS states that the fee will be refunded.
Recommended Next Steps
Hospice and home health organizations should promptly identify all pending and planned Medicare enrollment filings, including new enrollments, branch additions, practice-location changes, and ownership-related filings. For any filing submitted before May 13, providers should confirm whether the MAC received the application before such date and retain documentation of receipt.
Organizations pursuing acquisitions should revisit transaction timelines, closing conditions, regulatory covenants, and termination rights. Deal teams should determine whether the transaction structure triggers a new Medicare enrollment, whether the target is within the 36-month CIMO window, and whether any necessary enrollment approval may be unavailable during the moratoria.
Providers should also monitor state Medicaid and licensing developments. Although CMS has not imposed a mandatory Medicaid or CHIP moratorium, the agency is encouraging states to consider their own targeted actions. State-level responses could affect Medicaid participation, licensure, certification, or expansion plans even where Medicare enrollment is not immediately at issue.
Finally, existing providers should treat the announcement as a signal of heightened enforcement risk. Internal compliance reviews, ownership-record audits, referral-arrangement reviews, and billing-documentation audits should be prioritized, particularly for providers operating in markets CMS has identified as presenting elevated program-integrity concerns.
Conclusion
CMS's nationwide hospice and HHA moratoria represent a significant federal intervention in two provider sectors that have been central to recent program-integrity enforcement. While the moratoria are temporary, they may be extended and will have immediate effects on new entrants, expansion strategies, and certain transactions. Providers, investors, and lenders should assess pending filings and transaction structures now and prepare for continued CMS scrutiny throughout the moratoria period.