Medicare Enrollment Moratorium for Hospice and Home Health: What Existing Agencies Must Do to Stay Compliant

On May 13, 2026, the Centers for Medicare & Medicaid Services (CMS) implemented a temporary nationwide moratorium on the Medicare enrollment of new hospices and home health agencies (HHAs). CMS published two Federal Register notices on May 15, 2026, one for HHAs and one for hospices, explaining the rationale and scope of the moratoria. CMS described the action as part of a broader crackdown on fraud in coordination with the Vice President's anti-fraud task force.

This was the first nationwide enrollment moratorium for home health agencies and the first time CMS used its moratorium authority for hospices. It followed a nationwide moratorium on certain DMEPOS medical supply companies announced in February 2026.

For agencies already enrolled in Medicare, the most important message from CMS is that the moratoria affect new enrollments, not current enrollments. CMS stated that the moratoria will not impact current enrollments and that existing providers can continue to deliver services to Medicare beneficiaries. However, the moratoria do affect certain decisions that existing agencies may be considering, such as adding branches or practice locations and completing certain ownership changes. CMS also reminded existing agencies that their ongoing compliance obligations continue.

This article explains what the hospice and home health enrollment moratoria are, what they do and do not cover, how they affect existing agencies, and practical steps existing agencies can take to remain compliant during heightened scrutiny.

What Is a Medicare Enrollment Moratorium?

Section 6401 of the Affordable Care Act gave the Secretary of Health and Human Services authority to impose temporary moratoria on the enrollment of new Medicare, Medicaid, or CHIP providers and suppliers when necessary to prevent or combat fraud, waste, or abuse. CMS implemented this authority in regulations at 42 CFR 424.570.

Key features of a moratorium under 42 CFR 424.570 include:

• Length. A moratorium remains in effect for six months and may be extended in six-month increments if CMS deems it necessary. CMS evaluates whether to extend or lift the moratorium before the end of each period.

• Announcement. CMS announces a moratorium, and any extension or lifting, through a Federal Register notice.

• Lifting. CMS may lift a moratorium at any time for reasons including a presidential disaster declaration, abatement of the circumstances that warranted it, implementation of other safeguards, a public health emergency, or a determination by the Secretary that it is no longer needed.

• No judicial review. Under Section 1866(j)(7)(B) of the Social Security Act, there is no judicial review of the decision to impose a temporary enrollment moratorium.

• Denials. Under 42 CFR 424.530(a)(10) and 424.570(c), CMS denies enrollment applications from providers subject to a moratorium.

• No individual exceptions. CMS has stated that its regulations do not permit exceptions to a moratorium for individual providers or suppliers.

The 2026 Hospice and Home Health Moratoria at a Glance

According to CMS's Federal Register notices, its provider enrollment moratoria webpage, and its May 20, 2026 memorandum to state survey agencies:

• Effective date. The moratoria took effect May 13, 2026.

• Duration. The initial period is six months, running to mid-November 2026, and may be extended in six-month increments. Any extension or lifting will be announced in the Federal Register.

• Geographic scope. The moratoria apply nationwide, including all states, territories, and the District of Columbia.

• Covered applications. The moratoria apply to initial Medicare enrollment applications for hospices and HHAs, including new HHA branch locations and new hospice practice locations, and to non-exempt changes in majority ownership (CIMOs) that require initial enrollment.

• Pending applications. Applications received by the applicable Medicare contractor before May 13, 2026, continue to be processed.

• Denied applications. Initial applications submitted during the moratoria will be denied and must be resubmitted after the moratoria are lifted. Under 42 CFR 424.514, application fees are refunded when an application is denied because of a moratorium.

• Accreditation. During the moratorium, accreditation by a CMS-approved accrediting organization will not serve as a basis for Medicare enrollment of a prospective hospice or HHA.

• Medicaid and CHIP. The Medicare moratoria do not by themselves apply to Medicaid or CHIP, but CMS encouraged states to consider their own hospice moratoria and offered to consult with states.

Because the status of a moratorium can change, agencies should check CMS's provider enrollment moratoria webpage and the Federal Register for the latest information on whether the moratoria have been extended, modified, or lifted.

Why CMS Imposed the Moratoria

In its Federal Register notices, CMS explained that it had concluded, after consultation with the HHS Office of Inspector General (HHS-OIG), that hospices and HHAs present a significant potential for fraud, waste, or abuse. For HHAs, CMS described fraud, waste, and abuse as a severe problem for more than two decades, noting factors such as low start-up costs and the home-based nature of services. For hospices, CMS discussed recent increases in hospice enrollment in certain states, including Arizona, California, Georgia, Nevada, and Texas, and described measures it has taken to address hospice fraud.

CMS also reported related enforcement actions, including the suspension of payments to approximately 800 hospices and HHAs suspected of fraud in Los Angeles that were responsible for $1.4 billion in Medicare spending the prior year. CMS stated that during the moratoria it would intensify targeted investigations, deploy advanced data analytics, and accelerate the removal of hospices and HHAs suspected of fraud.

CMS stated that it does not believe the moratoria will threaten beneficiary access to hospice or home health services and that it will monitor for access issues, including in rural areas.

What the Moratoria Do Not Cover

Under 42 CFR 424.570(a)(1)(iii), as described in the Federal Register notices, a temporary moratorium does not apply to:

• Changes in practice location, except a move from a location outside the moratorium area to a location inside it. Because the 2026 moratoria are nationwide, this exception generally covers relocations within the United States, but agencies should confirm treatment with their Medicare contractor before moving.

• Changes in provider information, such as phone number or address.

• Changes in ownership, except changes in ownership of HHAs, hospices, and DMEPOS suppliers that would require an initial enrollment.

• Enrollment applications received by the Medicare contractor before the moratorium was imposed.

How the Moratoria Affect Existing Agencies

Continuing Operations

Existing Medicare-enrolled hospices and HHAs may continue to serve Medicare beneficiaries and bill Medicare. CMS has stated that the moratoria will not impact current enrollments.

Adding Branches and Practice Locations

The moratoria apply to new HHA branch locations and new hospice practice locations. CMS's HHA notice explains that CMS has always considered an HHA branch to be a practice location of the HHA, which is why branches are included. Existing agencies planning to expand by adding a new branch or practice location should expect those additions to be denied while the moratoria are in effect.

Changes in Majority Ownership and the 36-Month Rule

One of the most significant effects on existing agencies involves ownership changes. Under 42 CFR 424.550(b), if an HHA or hospice undergoes a change in majority ownership within 36 months after its initial enrollment or its most recent change in majority ownership, and no exception applies, it must enroll in Medicare as a new provider and undergo a state survey or accreditation. Its current enrollment and provider agreement are terminated.

CMS explained in the hospice notice that because this new enrollment is treated as an initial enrollment, the moratorium prevents a hospice undergoing a non-exempt CIMO from re-enrolling. The same principle applies to HHAs. In practical terms, an agency that completes a non-exempt CIMO during the moratorium could lose its Medicare enrollment without being able to re-enroll until the moratorium ends.

Agencies considering a sale, merger, acquisition, or investment should review carefully, with experienced legal counsel, whether the transaction would be a CIMO under 42 CFR 424.550(b), whether an exception applies, and how the timing interacts with the moratorium.

Other Ownership Changes

Ownership changes that do not require initial enrollment are generally not blocked by the moratoria, but they must still be reported accurately and on time. CMS has also proposed, in its CY 2027 Home Health Prospective Payment System proposed rule, new grounds to deny or revoke the enrollment of hospices, HHAs, and DMEPOS suppliers that fail to comply with the change in majority ownership requirements. Agencies should monitor whether these proposals are finalized.

Revalidation and Changes of Information

CMS's memorandum to state survey agencies stated that existing Medicare-certified hospices and HHAs should continue to comply with all change of information and revalidation reporting requirements, and that the moratoria affect only new enrollments, not ongoing compliance obligations.

Medicaid Considerations

Because the Medicare moratoria do not by themselves apply to Medicaid, agencies should check whether their state Medicaid program has imposed its own moratorium or additional requirements. CMS encouraged states to consider moratoria tailored to their populations.

After the Moratoria Are Lifted

Under 42 CFR 424.518, when a moratorium is lifted, providers of the affected type that apply for enrollment within six months afterward are assigned to the high screening risk level, which includes requirements such as fingerprint-based background checks for certain owners and site visits. Agencies planning new locations or transactions after the moratoria should prepare for enhanced screening.

Heightened Scrutiny During the Moratoria

The moratoria are one part of a broader set of CMS actions aimed at hospices and HHAs. CMS's announcement described additional measures, including:

• Revoking or deactivating hundreds of hospices and HHAs engaged in improper or fraudulent activity.

• Conducting nationwide hospice site visits to verify operations.

• Heightened oversight of newly enrolled hospices in states with elevated fraud risk, including Arizona, California, Georgia, Ohio, Nevada, and Texas.

• A new publicly available hospice scoring system to identify providers with troubling patterns of utilization, quality, or compliance.

• Enhanced enrollment screening for high-risk HHAs, including site verification and fingerprint-based background checks.

CMS also began deactivating hospices that have not billed Medicare for six consecutive months in March 2024 and extended that approach to home health agencies in January 2026, according to CMS's 2026 provider enrollment compliance conference materials. In addition, CMS's Fraud Defense Operations Center reported more than $23 million in suspended payments to suspect hospice providers in the first half of 2026.

For existing agencies, this means a greater likelihood of site visits, medical review, data analysis of billing patterns, and enrollment verification.

Key Dates and Related Actions

The following timeline, drawn from CMS announcements, places the hospice and home health moratoria in context:

• March 2024: CMS began deactivating hospices that had not billed Medicare for six consecutive months under its non-billing criteria.

• January 2026: CMS extended the six-month non-billing deactivation approach to home health agencies.

• February 27, 2026: CMS published a notice announcing a six-month nationwide moratorium on the enrollment of DMEPOS medical supply companies.

• May 13, 2026: The nationwide hospice and home health enrollment moratoria took effect.

• May 15, 2026: CMS published the hospice and HHA moratorium notices in the Federal Register.

• May 20, 2026: CMS issued a memorandum to state survey agencies explaining the moratoria and reminding existing agencies of their ongoing obligations.

• July 2026: CMS published its CY 2027 Home Health Prospective Payment System proposed rule, which included proposed provider enrollment changes affecting hospices, HHAs, and DMEPOS suppliers.

• Mid-November 2026: The initial six-month moratorium period ends unless CMS extends or modifies it through a Federal Register notice.

Planning for the End of the Moratoria

Whether CMS lifts, extends, or modifies the moratoria, existing agencies benefit from planning ahead.

If the moratoria are lifted, agencies that want to add branches, practice locations, or complete transactions should expect high-level screening for applications submitted within six months afterward. That means preparing for site visits, fingerprint-based background checks for certain owners, and detailed review of ownership and managing employee information. Applications should be complete and accurate from the start, because errors can lead to delays or denials.

If the moratoria are extended, agencies should revisit expansion and transaction plans, update timelines, and consider alternatives that do not require initial enrollment, while confirming compliance with all reporting requirements.

In either case, agencies should continue to monitor the Federal Register, CMS's provider enrollment moratoria webpage, and their state Medicaid agency's announcements, and should document internal decisions about how they are responding.

What Existing Agencies Must Do to Stay Compliant

1. Keep Enrollment Information Accurate and Current

• Review your Form CMS-855A enrollment information in the Provider Enrollment, Chain, and Ownership System (PECOS).

• Confirm that owners, managing employees, and practice locations are accurately reported. CMS has clarified that hospice medical directors and administrators qualify as managing employees and must be reported on the hospice's CMS-855A.

• Report changes within the timeframes required by 42 CFR 424.516.

• Track your revalidation due date on CMS's Medicare Revalidation List and respond promptly to revalidation notices.

2. Avoid Inadvertent Enrollment Problems

• Do not let billing lapse for extended periods without understanding the consequences, because hospices and HHAs that do not bill for six consecutive months may be deactivated under CMS's non-billing criteria.

• Make sure any relocation is reported correctly and confirmed with your Medicare contractor.

• Do not operate or bill from unreported locations.

3. Review Planned Transactions Carefully

• Before signing any sale, merger, investment, or restructuring agreement, evaluate whether the transaction is a change in majority ownership under 42 CFR 424.550(b).

• Check the date of your initial enrollment and most recent CIMO to see whether the 36-month rule applies.

• Consider whether timing changes, deal structure, or exceptions are available, with experienced counsel.

• Build moratorium contingencies into transaction documents.

4. Prepare for Site Visits

• Make sure your practice location matches your enrollment record, is staffed during posted hours, and has required signage.

• Train staff on how to receive a site visitor, verify identification, and notify leadership.

• Keep licenses, accreditation documentation, staffing records, and policies readily available.

5. Strengthen Clinical Documentation

For hospices:

• Confirm that documentation supports terminal prognosis, certification and recertification requirements, face-to-face encounters when required, and the plan of care.

• Make sure the election statement and the election statement addendum requirements are met. CMS has announced that providing the hospice election statement addendum is becoming mandatory under a final rule published in August 2026, rather than only upon patient request.

• Monitor length of stay, live discharge rates, and patterns that may draw attention.

For home health agencies:

• Confirm documentation of homebound status, the face-to-face encounter, the plan of care, and certification by an allowed practitioner.

• Confirm that visits are documented accurately and match the plan of care.

6. Monitor Billing Data

• Review comparative data such as CMS's Program for Evaluating Payment Patterns Electronic Report (PEPPER), which is available for hospices and HHAs.

• Investigate and document reasons for significant changes in volume, case mix, or referral sources.

• Watch for claims submitted under your identifiers that you did not submit.

7. Screen Your Workforce and Vendors

• Screen employees, contractors, and vendors against the HHS-OIG List of Excluded Individuals and Entities, SAM.gov, and state Medicaid exclusion lists.

• Verify licenses and credentials for all clinical staff.

8. Review Referral and Marketing Practices

• Confirm that relationships with physicians, facilities, and marketers comply with the Anti-Kickback Statute and, where applicable, the Stark Law.

• Avoid recruiting patients through inducements or high-pressure tactics.

9. Maintain an Effective Compliance Program

Use HHS-OIG's General Compliance Program Guidance as a benchmark, and conduct a risk assessment focused on the hospice and home health risks identified by CMS and HHS-OIG.

10. Have an Audit and Payment Suspension Response Plan

Because CMS has increased payment suspensions and revocations in the hospice and home health sectors, agencies should have a written plan for responding to records requests, site visits, payment suspensions, and revocation notices, including the involvement of experienced counsel.

Frequently Asked Questions

Does the moratorium affect my existing hospice or home health agency?

Existing enrollments are not affected, and existing agencies can continue serving Medicare beneficiaries. However, the moratoria block new branches or practice locations and non-exempt changes in majority ownership that require initial enrollment.

Can I add a new branch during the moratorium?

New HHA branch locations and new hospice practice locations are covered by the moratoria, so applications to add them are expected to be denied while the moratoria are in effect.

Can I sell my agency during the moratorium?

It depends on the structure and timing. A non-exempt change in majority ownership within 36 months of initial enrollment or the most recent CIMO requires initial enrollment and is blocked by the moratorium. Other ownership changes may be possible but must be reported correctly. Consult experienced counsel before proceeding.

Do I still need to revalidate?

Yes. CMS has stated that existing hospices and HHAs must continue to comply with revalidation and change of information requirements.

When will the moratoria end?

The initial six-month period runs to mid-November 2026. CMS may extend the moratoria in six-month increments or lift them, and will announce any change in the Federal Register.

Can I appeal a denial based on the moratorium?

Under the Social Security Act, there is no judicial review of CMS's decision to impose a moratorium, and CMS regulations do not permit individual exceptions.

Conclusion

The 2026 nationwide Medicare enrollment moratoria for hospices and home health agencies are designed to stop new entrants in sectors CMS considers high risk for fraud, waste, and abuse. Existing agencies can continue operating, but they face real constraints on expansion and certain ownership changes, along with heightened oversight through site visits, data analytics, non-billing deactivations, and payment suspensions.

Existing agencies can protect themselves by keeping enrollment information accurate, meeting revalidation and change reporting requirements, reviewing transactions carefully in light of the 36-month rule, preparing for site visits, strengthening documentation, monitoring billing patterns, and maintaining an effective compliance program. These steps support compliance during the moratoria and position agencies well for whatever comes next.

How HealthBridge Can Help

HealthBridge is a healthcare management consulting firm that specializes in hospice and home health compliance, Medicare enrollment, and audit readiness. We help agencies review enrollment and ownership records, evaluate how planned changes may be affected by the moratoria, prepare for site visits, strengthen clinical documentation, and build compliance programs that stand up to scrutiny. If you would like help keeping your agency compliant during the moratoria, please get in touch with us. We will be happy to help you with this topic.

References

• Federal Register. Medicare, Medicaid, and Children's Health Insurance Programs: Announcement of Nationwide Temporary Moratorium on Enrollment of Hospices (May 15, 2026). https://www.federalregister.gov/documents/2026/05/15/2026-09718/medicare-medicaid-and-childrens-health-insurance-programs-announcement-of-nationwide-temporary

• Federal Register. Medicare, Medicaid, and Children's Health Insurance Programs: Announcement of Nationwide Temporary Moratoria on Enrollment of Home Health Agencies (HHAs) (May 15, 2026). https://www.federalregister.gov/d/2026-09717

• Centers for Medicare & Medicaid Services. Provider Enrollment Moratoria. https://www.cms.gov/medicare/enrollment-renewal/providers-suppliers/chain-ownership-system-pecos/provider-enrollment-moratoria

• Centers for Medicare & Medicaid Services. CMS Announces Aggressive Nationwide Crackdown on Fraud with Six-Month Hospice and Home Health Agency Enrollment Moratoria. https://www.cms.gov/newsroom/press-releases/cms-announces-aggressive-nationwide-crackdown-fraud-six-month-hospice-home-health-agency-enrollment

• Centers for Medicare & Medicaid Services. QSO-26-11-HHA/Hospice: Six-Month National Moratoria on Hospice and Home Health Agency Enrollment (May 20, 2026). https://www.cms.gov/files/document/qso-26-11-hha-hospice-original-release-2026-05-20.pdf

• Centers for Medicare & Medicaid Services. Home Health and Hospice Nationwide Moratorium Q&As. https://www.cms.gov/files/document/hh-hospice-moratorium-faqs.pdf

• Centers for Medicare & Medicaid Services. Hospice News and Announcements. https://www.cms.gov/hospice-news-announcements

• Centers for Medicare & Medicaid Services. Crushing Fraud Spotlight: Medicare Enrollment Moratoria Target Home Health, Hospice, and DMEPOS Suppliers. https://www.cms.gov/files/document/cpi-moratoria-fast-facts.pdf

• Centers for Medicare & Medicaid Services. Crushing Fraud, Waste, and Abuse. https://www.cms.gov/fraud

• Centers for Medicare & Medicaid Services. Medicare Provider Enrollment Compliance Conference Keynote (March 2026). https://www.cms.gov/files/document/2026-cms-keynote-present-future-provider-enrollment.pdf

• Federal Register. Calendar Year 2027 Home Health Prospective Payment System Rate Update; Medicare Provider Enrollment and DMEPOS Policies, Proposed Rule (July 6, 2026). https://www.federalregister.gov/documents/2026/07/06/2026-13602/calendar-year-2027-home-health-prospective-payment-system-hh-pps-rate-update-requirements-for-the-hh

• Centers for Medicare & Medicaid Services. Crushing Fraud through the Fraud Defense Operations Center, Fast Facts (CY 2026 update). https://www.cms.gov/files/document/cpi-fdoc-fact-sheet-updated-first-year.pdf

• Centers for Medicare & Medicaid Services. Medicare Revalidation List. https://data.cms.gov/tools/medicare-revalidation-list

• Electronic Code of Federal Regulations. 42 CFR 424.570, Moratoria on Newly Enrolling Medicare Providers and Suppliers. https://www.ecfr.gov/current/title-42/section-424.570

• Electronic Code of Federal Regulations. 42 CFR 424.550, Prohibitions on the Sale or Transfer of Billing Privileges. https://www.ecfr.gov/current/title-42/section-424.550

• Electronic Code of Federal Regulations. 42 CFR 424.518, Screening Levels for Medicare Providers and Suppliers. https://www.ecfr.gov/current/title-42/section-424.518

• Electronic Code of Federal Regulations. 42 CFR 424.516, Additional Provider and Supplier Requirements for Enrolling and Maintaining Active Enrollment Status. https://www.ecfr.gov/current/title-42/section-424.516

• Electronic Code of Federal Regulations. 42 CFR 424.530, Denial of Enrollment in the Medicare Program. https://www.ecfr.gov/current/title-42/section-424.530

• U.S. Department of Health and Human Services, Office of Inspector General. Hospice Featured Topic. https://oig.hhs.gov/reports/featured/hospice/

• U.S. Department of Health and Human Services, Office of Inspector General. General Compliance Program Guidance. https://oig.hhs.gov/compliance/general-compliance-program-guidance/

• U.S. Department of Health and Human Services, Office of Inspector General. Exclusions Program and LEIE Database. https://oig.hhs.gov/exclusions/