CMS Imposes Nationwide Enrollment Freeze for Home Health Agencies and Hospices

On May 13, 2026, the Centers for Medicare & Medicaid Services (CMS) issued a press release and a Federal Register notice announcing a nationwide moratorium on the enrollment of new home health agencies (HHAs) and hospices, effective immediately. Under the moratorium, new providers are barred from enrolling in Medicare as HHAs or hospices for a six-month period. This temporary moratorium represents a significant program integrity measure and marks a notable shift from CMS’s historical practice of imposing targeted, regional restrictions. Instead, CMS has adopted a broader, system-wide approach to address perceived vulnerabilities in the home health and hospice sectors. As noted in the Federal Register notice, the moratorium is intended to prevent fraud “before it begins, rather than after the fact,” underscoring a shift toward preemptive oversight.

Scope of the Moratorium 

The moratorium applies to new HHAs and hospices seeking to enroll in Medicare on or after May 13, 2026, and initial enrollment applications submitted on or after that date will be denied for the moratorium’s duration. Consistent with 42 C.F.R. §§ 424.570(a) and 424.550(b), the moratorium extends to all initial enrollment applications, including certain ownership changes that require a new Medicare enrollment. 

In fact, entities considering transactions involving HHAs need to be cautious of CMS’s “36-Month Rule” during the moratorium. Generally, under Medicare, traditional stock/equity acquisitions in which the provider’s tax identification number remains the same are not considered “change of ownership” under 42 C.F.R. § 424.550(b) requiring a new Medicare enrollment. However, there is an exception for HHAs.  For HHAs, a change in the majority equity ownership (CIMO) of an HHA within 36 months after the HHA’s initial enrollment (or its most recent CIMO) will require the HHA to enroll as a brand new HHA provider (the “36-Month Rule”). CMS confirmed in recent FAQs that, unless an exception is met, such enrollments subject to the 36-Month Rule would be subject to the moratorium.

Applications received by a Medicare contractor prior to the effective date of the moratorium are not subject to the moratorium and may continue through review. The moratorium does not apply to enrollment renewals or updates for existing providers. Medicare-enrolled HHAs and hospices may continue operating and may update enrollment information, including changes to addresses, phone numbers, and other provider details, as permitted under 42 C.F.R. § 424.570(a)(1)(iii) without triggering the moratorium.

CMS’s Rationale

CMS cited concerns of fraud, waste, and abuse as its reasoning for the moratorium, with an emphasis on preventing improper activity before it occurs. In the Federal Register notice, CMS explained that it determined there is a “significant potential for fraud, waste or abuse” in the home health and hospice sectors, warranting the use of its moratorium authority. The agency pointed to indicators of program vulnerability, including rapid growth in provider enrollments in certain markets and patterns suggesting  improper billing practices and inappropriate or unauthorized Medicare beneficiary enrollments. CMS explained that a nationwide approach is warranted given the significant potential for fraud, waste, and abuse in these sectors, and indicated that it will consider beneficiary access to care in administering the moratorium.

Looking Forward

Under 42 C.F.R. § 424.570(b), the moratorium will remain in effect for an initial period of six months, but CMS may extend it in successive six-month increments if it determines that continued program integrity risks warrant doing so, with any extension announced through publication in the Federal Register. Historical practice suggests that such extensions are a meaningful possibility. Beginning in 2013, CMS imposed and repeatedly extended targeted moratoria on home health agencies and ambulance suppliers in high-risk geographic areas, including counties in Florida, Illinois, Texas, Michigan, Pennsylvania, and New Jersey, before those restrictions ultimately expired in January 2019. More recently, in February 2026, CMS implemented a separate nationwide moratorium on certain durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) suppliers, further illustrating the agency’s growing willingness to deploy this authority on a broad scale.

Against this backdrop, HHAs and hospices should anticipate that the current nationwide moratorium may extend beyond its initial term and should plan accordingly. More broadly, the moratorium reflects CMS’s evolving and more proactive approach to program integrity, which is likely to have ongoing implications for enrollment, transactions, and compliance across the sector. Although CMS has not indicated that it intends to impose similar nationwide moratoria for Medicaid or CHIP at this time, federal law generally requires states to comply with CMS-imposed moratoria unless doing so would adversely affect beneficiary access to care. CMS has also encouraged states to consider whether comparable measures may be appropriate within their jurisdictions.

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