CMS Nationwide Moratoria on New Hospice and Home Health Medicare Enrollments: Covered Entities, Industry Impact

This CLE webinar will examine the six-month moratoria recently enacted by CMS on new Medicare enrollments for hospice and home health agencies (HHAs). The panel will discuss the moratoria scope and impact on the healthcare industry including current and future healthcare transactions. The panel will also offer best practices for helping clients navigate the moratoria.

CMS recently enacted nationwide six-month moratoria on new Medicare enrollments for hospice and HHAs. The agency cites concern over fraud, waste, and abuse as the reason behind the moratoria and describes more stringent enforcement measures to be enacted in an attempt to eliminate fraud in this sector.

The moratoria affect not only new enrollments, but also the addition of new branches or practice locations. The moratoria may also apply to certain changes in location and certain transactions and changes in ownership.

Counsel and clients should understand the full impact of the moratoria on healthcare transactions, operations, and finances. For example, pending enrollment applications received by a Medicare Administrative Contractor prior to the effective date of May 13, 2026 should not be affected by the moratoria. However, entities planning new hospice or HHA operations should treat those plans as suspended, which may then impact deals already in progress. And even where a transaction may remain viable during the moratoria period, enhanced due diligence of the target's compliance history may be in order given the heightened scrutiny and enforcement activity expected.

Furthermore, while the moratoria are aimed at hospice and HHAs, the impact may have ripple effects throughout the healthcare industry as many hospitals and healthcare providers rely on these organizations in operational support roles such as for discharge planning, continuity of care, post-acute services, and end-of-life care.

Listen as our authoritative panel of healthcare attorneys examines the CMS moratoria and the potential impact on the healthcare industry. The panel will discuss the moratoria scope, address how current and future transactions may be affected, and offer best practices for navigating the new moratoria and heightened enforcement activity.