Hospice and Home Health Moratorium 2026: What to Do Before the November 13 Decision

Will the hospice and home health moratorium end on November 13, 2026?

The hospice and home health moratorium is a CMS freeze on new Medicare enrollment of home health agencies and hospices that took effect May 13, 2026, and runs through about November 13, 2026. As of late October 2026, CMS had not published an extension notice. It can still extend the freeze in six-month increments or let it expire, and enrolled agencies keep billing either way.

• If CMS extends: New agencies, new hospice locations, new HHA branches, and ownership changes that require new enrollment stay frozen for at least six more months.
• If it expires: Expect a filing surge, high-risk screening, and survey backlogs, so applicants with finished paperwork move first.
• Either way: Build your CMS-855A package, ownership disclosures, and accreditation plan now.

What the CMS Moratorium Froze in May

On May 13, 2026, CMS imposed two six-month nationwide moratoria on new Medicare enrollment, one for home health agencies (HHAs) and one for hospices. The HHA notice (CMS-6101-N) and the hospice notice (CMS-6102-N) were published in the Federal Register on May 15, 2026, and they cover every state and U.S. territory. Both took effect the day CMS announced them.

The freeze reaches further than brand-new agencies. It blocks initial enrollment applications, new hospice practice locations, and new HHA branches. It also blocks changes in majority ownership that require a new enrollment under the 36-month rule, which applies when an agency changes majority ownership within 36 months of its initial enrollment or its most recent majority ownership change. According to CMS’s moratorium FAQs, initial applications submitted during the moratorium are denied and must be resubmitted after it lifts.

What it leaves alone matters just as much. Agencies already enrolled keep billing Medicare. Applications that a Medicare Administrative Contractor received before May 13 continue through processing, and CMS’s May 20 memo to state survey agencies states that its regulations do not permit exceptions. Routine changes to an existing enrollment, including practice location changes, are still processed, although they may draw closer review.

Federal rules set the clock. Under 42 CFR 424.570(b), a moratorium lasts six months, CMS may lift it early, and any extension comes in six-month increments announced in the Federal Register. That places the first decision point at about November 13, 2026. If CMS extends the freeze, the next decision point would fall around mid-May 2027.

Who does the hospice and home health moratorium apply to?

The hospice and home health moratorium applies to any organization seeking a new Medicare enrollment as a home health agency or hospice, including new HHA branches, new hospice practice locations, and buyers whose majority ownership change triggers a new enrollment. Currently enrolled agencies, and applications received before May 13, 2026, are not affected.

Start-up agencies. Owners who lined up licenses, leases, staff, and capital for a new agency have been unable to obtain a Medicare enrollment since May, and many are carrying overhead while they wait.

Expanding agencies. An enrolled hospice cannot add a practice location, and an enrolled HHA cannot add a branch, until the freeze ends.

Buyers and sellers. CMS states that an ownership change requiring new enrollment under the 36-month rule will be denied during the moratorium, which has put many deals on hold. Transactions that do not trigger a new enrollment can still be reported as ownership changes, so structure and timing decide which side of the line a deal falls on.

Medicaid runs on a separate track. The federal freeze covers Medicare enrollment, and states decide on their own Medicaid moratoria. Rhode Island’s Medicaid program imposed a six-month moratorium on newly enrolling hospice and home health providers from July 1, 2026, to January 1, 2027, and New York’s six-month freeze announced in July includes licensed home care services agencies, as we covered in our report on the New York Medicaid enrollment moratorium. Check your state Medicaid agency’s notices directly, because state freezes can start and end on different dates than the federal one.

Why CMS Imposed It and What It Signals

CMS tied the freeze to fraud risk. Its notices pointed to sharp growth in new hospice and home health enrollments in states including Arizona, California, Nevada, Michigan, North Carolina, and Texas, along with criminal fraud cases in both sectors. It was the first nationwide enrollment freeze for home health agencies and the first time CMS used its moratorium authority on hospices. Before this year, CMS relied on targeted moratoria in specific metro areas, which it imposed and extended between 2013 and 2018.

The move fits a broader pattern. A nationwide moratorium on certain DMEPOS suppliers ran from February 27 to August 27, 2026, and CMS let it lapse without an extension, as we covered when the DMEPOS enrollment moratorium lifted. That outcome is one data point, not a prediction.

Industry pressure points toward expiration. The National Alliance for Care at Home asked CMS in a September 9 letter to end the freeze at six months, and LeadingAge and the National Partnership for Healthcare and Hospice Innovation made similar requests. CMS told stakeholders it would give about 60 days’ notice of an extension, McKnight’s Home Care reported in July, and that window passed in mid-September without a published notice.

Expiration would not end the scrutiny. CMS’s proposed CY 2027 home health rule, published July 6, 2026, would make all Medicare revocations retroactive to the date noncompliance began and would let CMS revoke an enrollment that presents high fraud risk because the provider sits in a limited geographic area with an excessive number of providers. Those provisions are proposed, not final. Our analysis of the proposed revocation changes explains what they would mean for every provider type.

What happens if CMS lets the moratorium expire?

If CMS lets the moratorium expire, new home health and hospice enrollment applications can be filed again, but agencies that were blocked and apply within six months of the lift are screened at the high-risk level. That means fingerprint-based background checks for owners and site visits, on top of survey or accreditation requirements.

For a new HHA, little changes on paper, because CMS already screens newly enrolling home health agencies at the high-risk level. High-risk screening adds fingerprint-based criminal background checks for every individual with a 5% or greater ownership interest, plus site visits, to the standard enrollment review.

The bigger issue is volume. An attorney interviewed by Home Health Care News in October said an expiration could create a bottleneck as providers try to catch up on delayed plans. That backlog would show up in contractor processing queues, site visit scheduling, and survey or accreditation calendars. In our experience, the applications that move fastest after any moratorium are the ones fully assembled before it ended.

A narrower outcome is possible. CMS said in its May notice that it considered a targeted geographic moratorium for HHAs before choosing a nationwide one.

How should home health agencies and hospices prepare now?

Home health agencies and hospices should prepare now by assembling a complete CMS-855A package, documenting every owner and managing employee, confirming accreditation or survey plans, and checking state licensure and Medicaid rules. Agencies that finish this work before November 13 can file the day enrollment reopens instead of starting from scratch.

1. Assemble the CMS-855A package. Prepare the application in PECOS with legal business name, tax ID, and NPI data that match IRS and NPPES records exactly.
2. Document every owner and managing employee. List all individuals and organizations with a 5% or greater direct or indirect ownership interest, since each individual owner faces fingerprinting.
3. Prove capitalization for a new HHA. Have initial reserve operating funds documented and ready, because CMS reviews HHA capitalization at initial enrollment.
4. Lock in your survey path. Choose a CMS-approved accrediting organization or confirm state survey timing, since no agency bills Medicare before certification.
5. Prepare the site for an unannounced visit. Keep the location staffed, accessible, and clearly identified during posted business hours.
6. Map the 36-month rule for any deal. Confirm whether a pending ownership change would require new enrollment, and time the closing accordingly.
7. Check state Medicaid status separately. Confirm whether your state is running its own Medicaid moratorium before projecting Medicaid revenue.
8. Budget for the application fee. Institutional providers pay $750 per application submitted in calendar year 2026.

Every application we prepare is audited by a specialist before submission, and that review matters most when contractors are working through a surge. The question we hear most from home health and hospice owners right now is whether they can file the day the freeze ends. They can, if the package is complete.

Common Misreadings of the Moratorium

Across the enrollment questions we field, the same misunderstandings keep coming up, and each one can cost an agency weeks once filing reopens.

Expiration means automatic approval. It means applications are accepted again. Screening, surveys, and contractor processing still apply, and high-risk screening adds steps, so plan for weeks of review rather than days.

An application filed now holds a place in line. CMS denies initial applications submitted during the moratorium, and they must be resubmitted after it lifts. There is no waitlist, so the filing date after the lift is what counts.

Medicare and Medicaid move together. The federal freeze covers Medicare. State Medicaid moratoria set their own dates, like Rhode Island’s January 1, 2027, end date, and New York’s July freeze runs on its own timeline.

Enrolled agencies are frozen too. Existing agencies keep billing and can report routine changes. What they cannot do is add a hospice practice location or an HHA branch until the freeze ends.

Every acquisition is blocked. Only ownership changes that require new enrollment under the 36-month rule are denied. Deal structure and timing decide the outcome, so finish the 36-month analysis before signing a purchase agreement.

Accreditation can wait until enrollment is approved. An agency cannot bill Medicare until it is certified through a state survey or a CMS-approved accrediting organization, so survey scheduling belongs in the plan now, not after filing.

The proposed 2027 enrollment rules are already in force. Retroactive revocations and the geographic revocation authority remain proposals until CMS publishes a final rule, which for the home health payment rule usually comes late in the year.

Frequently Asked Questions

Next Steps

Clear the usual causes of delay first with our guide to avoiding delays in Medicare provider enrollment.

Serving Medicaid patients too? See what the CMS Medicaid revalidation mandate means for enrolled agencies.

Ready to file when enrollment reopens? Our Medicare provider enrollment team prepares and audits CMS-855A applications.