Volume 26.01
Effective today, May 13, 2026, the U.S. Centers for Medicare & Medicaid Services (“CMS”) has issued a Notice and imposed a national six (6) month moratorium on the Medicare enrollment of home health agencies.
Beginning on May 13, 2026, no new HHAs or HHA branches or practice locations will be enrolled into Medicare unless the HHA’s enrollment application was received by the applicable Medicare contractor prior to May 13, 2026.
The moratorium does not apply to:
- Changes in practice location, except the addition of a new location,
- Change in provider or supplier information on file,
- Change in ownership except those which would require the submission of an initial enrollment, and
- Any enrollment received by the Medicare contractor prior to May 13, 2026.
CMS is currently allowing each State to decide whether some form of a home health provider moratorium is appropriate for their respective Medicaid and CHIP programs, and the scope of any such moratorium.
A provider or supplier that is impacted by a moratorium may use the existing appeal procedures at 42 CFR part 498 to administratively appeal a denial of billing privileges based on the imposition of a temporary moratorium. The scope of any such appeal, though, would be limited solely to assessing whether the temporary moratorium applies to the provider or supplier appealing the denial.
CMS stated, “There are two principal alternatives we considered in preparing this notice. First, we considered forgoing a moratorium entirely. Yet as already mentioned, the longstanding fraud, waste, and abuse problems require fraud, waste, and abuse prevention measures beyond those described earlier in this notice, such as capitalization requirements. Helpful though the latter have been, more is needed. Second, we contemplated limiting the moratorium to southern California. We believe, though, that the problems the moratorium seeks to address are nationwide rather than restricted to particular geographic areas. As we also stated earlier, the transient nature of fraud schemes – as shown in, for instance, the sudden upswing in new HHAs in Los Angeles County and the tens of HHAs in Ohio operating out of single site – require nationwide (rather than localized) proactivity to prevent these schemes from developing in the first place.”
The Notice is available here.
Further information will be provided regarding the moratorium and its implementation. Do not hesitate to contact us at contact@healthgroup.com with your questions regarding this matter.