CMS Enrollment Moratoria: Change of Ownership Implications for Home Health and Hospice Transactions
- July 10, 2026
- Hedy Rubinger , Arnall Golden Gregory LLP
- Jessica Grozine , Arnall Golden Gregory LLP
- Maggie Callahan , Arnall Golden Gregory LLP
The Centers for Medicare & Medicaid Services (CMS) has implemented nationwide six‑month enrollment moratoria on new home health agencies (HHAs) and hospices, including new branches and practice locations. CMS framed these moratoria, implemented on May 13, as part of a broader program integrity strategy to address fraud, waste, and abuse by pausing new enrollments while the agency intensifies oversight. Although the moratoria do not terminate existing enrollments or prohibit all transactional activity, they substantially alter the risk calculus for buyers, sellers, and investors.
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