Hospice and Home Health Moratoria | CHAP Hospice and Home Health Moratoria

CMS Hospice & Home Health Moratorium: What CHAP Knows So Far

Last updated: May 21, 2026 at 1:00 PM ET

This page is CHAP’s primary reference point regarding the CMS Hospice and Home Health enrollment moratorium. It is intended for providers, partners, and the general public, and may also be used by CHAP staff when responding to questions.

CHAP is updating this page as frequently as possible based on official CMS guidance and publicly available information. We will not speculate or provide guidance beyond what CMS has clearly communicated.

Summary of the CMS Moratorium

On May 13, 2026, the Centers for Medicare & Medicaid Services (CMS) announced a national moratorium on the enrollment of new Medicare Hospice and Home Health agencies. The moratorium applies to Medicare enrollment only and is part of CMS’s broader program integrity efforts.

Based on CMS guidance to date:

The moratorium restricts new Medicare enrollments for Hospice and Home Health agencies.

It does not automatically apply to all providers or all enrollment scenarios.

Certain applications received by CMS prior to the moratorium date may continue to be processed, depending on their status.

State licensure, Medicaid, and CHIP programs are handled separately and may vary by state.

CMS has indicated that this moratorium is intended as a time‑limited (6‑month) enrollment restriction, not a shutdown of existing providers.

Read the CHAP summary published on May 14, 2026

Webinar Recording

CHAP hosted an informational webinar discussing the CMS moratorium, including what has been confirmed and what remains unknown.

This moratorium applies specifically to Medicare enrollment. CHAP discussed confirmed information and open questions during the webinar above.

View Recorded Webinar

How to Use This Page

This page is designed to provide clear, consistent information based solely on confirmed CMS guidance.

For Providers, Partners, and the Public

This page reflects only what CMS has confirmed as of the date and time listed at the top of the page.
Not all possible scenarios are addressed individually. Whether and how the moratorium applies depends on a provider’s specific Medicare enrollment status and the timing of their application.
This page does not provide legal, regulatory, or business advice and should not be used as a substitute for official CMS communications.
Information may change as CMS issues additional clarification.

CHAP will update this page as new CMS guidance becomes available.

What CHAP Knows Right Now

The following reflects what CMS has confirmed as of the date listed above.

Medicare Enrollment

The moratorium applies to new Medicare enrollments for Hospice and Home Health.

Enrollment applications received by CMS prior to the moratorium effective date may not be subject to the moratorium, consistent with federal regulation (§424.570).

CMS evaluates each application based on its individual enrollment status, including whether a Document Control Number (DCN) has been issued or whether an 855A recommendation letter has been received.

Accreditation and Surveys

Accreditation activity is not automatically suspended by the CMS moratorium.

Providers with a DCN and an 855A recommendation letter or MAC receipt of the 855A application may still be eligible to move forward in the accreditation process based on CMS rules.

CMS has not indicated that previously completed, valid accreditation surveys are invalid solely due to the moratorium.

Providers Already in Process

CMS has acknowledged that providers affected by the moratorium may already:
- Hold a state license
- Serve patients
- Be mid‑process with Medicare enrollment or accreditation

CMS guidance distinguishes between applications already received by CMS and those not submitted before the moratorium took effect.

Medicaid and CHIP

CMS has stated that Medicaid and CHIP moratoria are state‑specific decisions.

Each state may determine whether to implement its own Hospice or Home Health moratorium for Medicaid or CHIP.

CMS is offering to consult with states, but requirements and impacts will vary.

State Licensure

The CMS moratorium applies to Medicare enrollment only.

State licensure is governed by state law and regulation and may continue independently of CMS Medicare enrollment.

Additional Resources

Home Health and Hospice Nationwide Moratorium Q&As  
CMS Press release – CMS Announces Aggressive Nationwide Crackdown on Fraud with Six-Month Hospice and Home Health Agency Enrollment Moratoria  
CMS Nationwide Hospice & Home Health Moratoria Guidance (QSO-26-11)
CHAP Blog: Hospice & Home Health Medicare Moratorium – What We Know So Far
CHAP’s formal response to CMS (in response to the Request for Information related to Comprehensive Regulations to Uncover Suspicious Healthcare, or CRUSH)

Frequently Asked Questions

These FAQs reflect only what CMS has publicly confirmed. CHAP does not speculate, interpret beyond CMS guidance, or provide legal or business advice. 

Moratorium Basics

Who does the national home health and hospice moratorium apply to, and who does it not apply to?

The following is applicable under the moratorium:

No new hospices or hospice practice locations will be enrolled in Medicare unless the hospice’s enrollment application was received by the applicable Medicare contractor prior to the effective date of 5/13/26.
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 this notice’s effective date.

Under § 424.570(a)(1)(iii), a temporary moratorium does not apply to any of the following:

Changes in practice location (except if the location is changing from a location outside the moratorium area to a location inside the moratorium area).
Changes in provider or supplier information, such as phone numbers or addresses.
Changes in ownership (except changes in ownership of home health agencies, hospices, or suppliers of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) that would require an initial enrollment).
Also, in accordance with § 424.570(a)(1)(iv), a temporary moratorium does not apply to any enrollment application that has been received by the Medicare contractor prior to the date the moratorium is imposed.

In the Q&A, it states: “CMS’ regulations do not permit exceptions to a moratorium for individual providers or suppliers” – Is this black and white and include providers in CON areas who had been waiting for approval to apply?

In addition to the statement above, the CMS FAQs state in Q6/A6: Providers/suppliers 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. However, the scope of any such appeal would be limited solely to assessing whether the temporary moratorium applies to the provider/supplier appealing the denial. Based on the information in the moratorium, A CON application is not likely to permit an appeal unless the provider has submitted the CMS enrollment application (855A) prior to May 13, 2026. CHAP is monitoring CMS communications and will update resources as clarification becomes available.

Applications & CMS Enrollment Status

If an application was submitted before the moratorium, is it still processed?

Yes. CMS states that, in accordance with 42 CFR §424.570(a)(1)(iv), the moratorium does not apply to an enrollment application package (CMS 855A) that has been received by the Medicare contractor prior to the date the moratorium is imposed (5/13/2026).

CMS, Palmetto GBA and NGA Wellpoint have confirmed that “enrollment received” by the Medicare Administrative Contractor (MAC) is the receipt date of an 855A. This means that the survey process may continue unless there is a state-specific restriction.
NOTE: If an 855A that has been submitted prior to 5/13/26 is denied by the MAC for valid reasons, a new application will not be accepted during the moratorium.
If a provider believes it was denied or rejected for invalid reasons, they can submit a rebuttal in accordance with the process outlined in the denial letter.

What happens if an application was submitted but not reviewed before the moratorium?

CMS states that the key factor is whether the enrollment application (CMS 855A) was received by the Medicare contractor prior to the moratorium date of 5/13/26. If it was received prior to the moratorium date of 5/13/26, the moratorium does not apply to that application. CMS also states that initial enrollment applications submitted during the moratorium (on or after 5/13/26) will be denied and will need to be resubmitted once the moratorium is lifted.

NOTE: If an 855A that has been submitted prior to 5/13/26 is denied by the MAC for valid reasons, a new application will not be accepted during the moratorium. If a provider believes it was denied or rejected for invalid reasons, they can submit a rebuttal in accordance with the process outlined in the denial letter.

Providers Already in Process

Accreditation & Surveys

Can a provider complete a deemed accreditation survey now and submit results later when the moratorium is lifted?

CMS deemed status: Medicare certification surveys may be conducted and processed during the moratorium, provided CMS/MAC has received the Medicare enrollment application (CMS 855A) prior to the effective date of 5/13/26. Deemed status accreditation and state agency Medicare certification surveys are forwarded to CMS, which will make the final determination on certification. This is unchanged from existing processes. Providers who have not submitted the CMS enrollment application prior to the deadline may choose non-deemed Home Health or Hospice Accreditation during the moratorium period. The provider will need to undergo a deemed accreditation survey once the moratorium is lifted. CHAP is tracking CMS updates and will revise its resources as new guidance becomes available.

Next Steps & Strategic Options

CMS states that initial enrollment applications submitted during the moratorium will be denied and must be resubmitted once the moratorium is lifted. CMS also notes that the moratorium typically does not affect existing enrolled providers and that they may continue to participate in Medicare and submit claims.

Other Payers (Non-Medicare)

Medicaid & CHIP

Ownership Changes & Organizational Changes

Change of Ownership (CHOW)

Under CMS regulations and the Moratorium Q&As, a temporary moratorium generally does not apply to changes in ownership unless the ownership change would require an initial enrollment. CMS explains that certain Changes in Majority Ownership (CIMO) within 36 months of initial enrollment (or most recent CIMO) trigger termination and require initial enrollment as a new provider; those situations would be subject to the moratorium.
NOTE: A CHOW is not triggered simply by a change in business form or administrative details. CMS evaluates operational and financial control rather than the transaction type. In some cases, a transaction may be considered a “change of information” (COI) instead of a CHOW, especially if:
- The taxpayer identification number (TIN) remains the same.
- The transaction does not alter majority ownership or control.
- The provider continues to operate under the same Medicare provider agreement.
- CMS/MAC will make the final determination as to whether a CHOW exists.

Can a person who just bought a home health agency, but has not filed his Medicare stock transfer 855A, still file it at this moment?

CMS will review the 855A and determine if a CHOW has occurred and/or initial enrollment is required. ICMS states that the key factor is whether the enrollment application (CMS 855A) was received by the Medicare contractor prior to the moratorium date of 5/13/26. However, if an 855A has not yet been submitted for the stock transfer, the application will be denied if CMS determines initial enrollment is needed.
NOTE: A CHOW is not triggered simply by a change in business form or administrative details. CMS evaluates operational and financial control rather than the transaction type. In some cases, a transaction may be considered a “change of information” (COI) instead of a CHOW, especially if:
- The taxpayer identification number (TIN) remains the same.
- The transaction does not alter majority ownership or control.
- The provider continues to operate under the same Medicare provider agreement.
- CMS/MAC will make the final determination as to whether a CHOW exists.

Open new practice locations (i.e., HHA branch, Hospice ADS, IPU)?

CMS’s Federal Register notices describe the moratorium as applying to hospice practice locations and to HHA branches and practice locations, and state that no new such entities will be enrolled unless the enrollment application was received by the Medicare contractor prior to the effective date (5/13/26). CMS also notes that, under the moratorium regulation, certain changes in practice location are not subject to the moratorium (with a stated exception when moving from outside to inside a moratorium area). CMS does not specifically define practice location for hospice as Alternate Delivery Site (ADS) or Inpatient Unit (IPU), however if a CMS 855A is required for the location, and the CMS 855A has not been received by May 13, 2026, it is presumed that the moratorium applies.

Stay Updated

We will continue updating this page as new guidance and operational updates become available to help providers stay informed and prepared.

Looking for education to support compliance and operational stability? Explore CHAP Learning Solutions courses and upcoming webinars.