CMS’s Hospice and Home Health Enrollment Moratorium: What Credentialing Teams Must Verify Before November 13

By Elena Pak, Credentialing Department, WCH

Editorial Note: This article addresses Medicare enrollment for home health agencies and hospices under the nationwide moratorium announced in May 2026. It does not establish requirements for Medicaid enrollment or commercial payer credentialing. The moratorium’s status and any subsequent CMS instructions should be verified immediately before publication and before an application is submitted.

November brings an important checkpoint for home health agencies (HHAs) and hospices seeking to enroll in Medicare. On May 13, 2026, the Centers for Medicare & Medicaid Services (CMS) imposed a six-month nationwide moratorium on new Medicare enrollment for both provider categories. Under the published terms, the initial period reaches its six-month mark in November, unless CMS extends or lifts the moratorium earlier.

For enrollment teams, the immediate task is not to assume that applications will reopen on a particular date. It is to establish which transactions remain prohibited, which activities existing Medicare-enrolled organizations may continue, and what documentation is needed to support the next enrollment action.

The distinction matters because the moratorium does not suspend every enrollment-related obligation. It restricts specified new enrollment activity while leaving existing providers subject to applicable reporting and compliance requirements.

What the Moratorium Actually Prohibits

CMS introduced the moratorium as a program-integrity measure in response to concerns about fraud, waste, and abuse in Medicare home health and hospice programs. It applies nationwide, including all states, territories, and the District of Columbia.

The restriction covers initial Medicare enrollment applications for new HHAs and hospices. It also applies to certain changes in majority ownership (CIMOs) that require an organization to enroll as a new provider under 42 CFR § 424.550(b), unless an applicable regulatory exception applies.

The timing of the original submission is important. CMS states that applications received by the applicable Medicare contractor before May 13, 2026, are not subject to the moratorium simply because they were pending when it took effect. Initial applications submitted during the moratorium, by contrast, will be denied and must be resubmitted once the restriction is lifted.

Credentialing and enrollment teams should therefore distinguish between an application already received before the effective date and a new application prepared or submitted afterward. A document package that is ready for submission does not establish that the application can be accepted.

Before taking action, confirm the relevant application type, the date the Medicare contractor received it, and whether the proposed transaction falls within the scope of the moratorium.

Existing Providers Still Have Enrollment Obligations

An enrollment moratorium is not a blanket suspension of Medicare participation. According to CMS, organizations already enrolled in Medicare can generally continue participating in the program, submit claims for covered services, and make certain changes to their enrollment information. Existing HHAs and hospices must also continue to comply with applicable changes-of-information and revalidation requirements.

This creates an important distinction for enrollment teams: a restriction on new enrollment does not eliminate the need to maintain accurate records for an existing provider.

Teams should continue to track required updates, revalidation deadlines, and other applicable reporting obligations. They should not postpone a required update merely because the organization cannot submit a new initial enrollment application.

At the same time, the team must distinguish routine updates from transactions that would effectively establish a new provider. The nature of the proposed change, not simply the fact that the organization already participates in Medicare, determines which rules apply.

A New Location Is Not Always a Routine Update

One of the most consequential details in CMS’s guidance concerns practice locations. The moratorium prohibits adding a new practice location to an existing HHA or hospice Medicare enrollment. This includes new branches, satellite offices, and expansion locations being added under an existing CMS Certification Number (CCN).

CMS generally permits certain changes to an existing practice location during a moratorium, but the exemption is not unconditional. A change of address does not automatically qualify as a continuation of existing operations.

CMS or the applicable State Survey Agency may assess whether the change represents a substantive operational shift. Relevant considerations include whether the organization has moved into a different geographic community, serves a new patient population, or operates with new clinical or administrative staff. If the change effectively establishes a new provider entity, the enrollment restriction may apply.

For credentialing and enrollment teams, the practical implication is clear: do not process every location change as an ordinary demographic update.

Before submitting a change, document the nature of the move, whether the organization is continuing its existing operations, and whether new locations or branches are involved. If the facts suggest that the transaction may establish a new provider, obtain clarification from the appropriate CMS contractor or State Survey Agency before proceeding.

The team should retain the supporting documentation and the resulting determination with the organization’s enrollment records.

Review Ownership Changes Before a Transaction Proceeds

Ownership changes require particular attention because some transactions can trigger an initial enrollment requirement. Under 42 CFR § 424.550(b), an HHA or hospice that undergoes a change in majority ownership within 36 months after its initial enrollment or most recent qualifying change in majority ownership generally must enroll as a new provider and undergo a state survey or accreditation, unless an exception applies. A transaction that requires new enrollment may therefore fall within the moratorium.

The rule does not mean that every acquisition or ownership change is automatically prohibited. CMS’s FAQ distinguishes changes that require a new enrollment from certain transactions involving already-enrolled organizations. Existing Medicare-enrolled providers may acquire or merge with other enrolled providers during the moratorium if the transaction does not trigger a non-exempt CIMO requiring new enrollment and does not add new locations. Existing locations transferred to the surviving entity’s enrollment as part of a qualifying acquisition or merger are not treated as new locations merely because the ownership structure changes.

Before an acquisition, merger, or ownership transfer proceeds, the enrollment team should establish:

The date of the organization’s initial enrollment and any previous qualifying change in majority ownership.

Whether the proposed transaction triggers the 36-month rule.

Whether a regulatory exception applies.

Whether the transaction requires a new initial enrollment application.

Whether new branches or practice locations are being added.

These questions should be resolved before the parties assume that the transaction can proceed under the existing Medicare enrollment.

If the proposed transaction appears to require new enrollment during the moratorium, the team should not assume that a routine change-of-information filing will resolve the issue. The transaction should be evaluated under the applicable regulations and CMS guidance before the enrollment documents are submitted.

Do Not Assume That an Individual Exception Is Available

CMS’s FAQ is explicit: the regulations do not permit individual providers or suppliers to receive an exception to the moratorium simply because their circumstances are unusual. An organization may use the applicable administrative appeal procedures after a denial of billing privileges based on the moratorium. However, CMS explains that the scope of such an appeal is limited to determining whether the moratorium applies to the provider or supplier. It is not a general process for obtaining permission to enroll despite an applicable restriction.

Enrollment teams should therefore determine whether the proposed application actually falls within the moratorium before submitting it. If an application is denied, preserve the denial notice, the application record, and any relevant supporting documentation. Review the stated basis for the decision and determine whether the issue concerns the scope of the moratorium or another enrollment requirement. This is more useful than submitting repeated applications without resolving the underlying eligibility question.

What to Do Before the Six-Month Mark

CMS moratoria are generally imposed for six months and may be extended in additional six-month increments. CMS states that extensions and the lifting of a moratorium are announced through a Federal Register notice.

The original six-month period reaches its scheduled endpoint in November 2026. However, the six-month mark should not be treated as an automatic reopening date. The enrollment team must verify whether CMS has published an extension, lifted the restriction, or issued additional instructions.

Before proceeding with a new application, take the following steps:

Check the official CMS moratorium page. Confirm the current status and review any linked Federal Register notices or updated guidance.

Verify the transaction type. Establish whether the planned action is a new initial enrollment, a non-exempt change in majority ownership, a permitted change to an existing enrollment, or a different transaction.

Review pending applications. Confirm the Medicare contractor’s receipt date and preserve evidence that an application was received before the moratorium took effect.

Keep existing enrollment records current. Continue to meet applicable revalidation and reporting obligations. Do not treat the moratorium as permission to delay required updates.

Prepare, but do not prematurely submit, a new application. Review the organization’s documents and identify any outstanding requirements. Submit only when the current CMS instructions permit the transaction.

Document the decision. Record the date of the status check, the source reviewed, the proposed transaction, and the basis for proceeding or holding the application.

These steps help ensure that a change in the moratorium’s status results in a deliberate enrollment decision rather than an assumption based on the passage of time.

The Enrollment Decision Comes Before the Submission

The hospice and home health moratorium creates different obligations for new applicants and organizations already participating in Medicare. The key task for credentialing teams is to identify the applicable category before deciding what to file.

A pending application received before the moratorium, a proposed new branch, a routine update to an existing record, and an ownership transaction are not interchangeable enrollment events. Each must be evaluated according to the relevant rules.

For November, the most important action is to verify the current CMS position before treating the scheduled six-month endpoint as permission to enroll. If the moratorium remains in effect, prohibited applications should not be submitted in the expectation that they will be held for later processing. If CMS lifts or changes the restriction, teams should follow the newly published instructions and confirm that the specific transaction is permitted.

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