The Future For Hospice, Home Health Providers Under CMS Moratoria
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CMS’s six-month moratoria blocking certain new Medicare enrollments and ownership changes for hospice and home health providers are scheduled to expire Nov. 13. The agency has not said whether it will extend them, leaving providers uncertain about delayed openings, expansion plans and transactions.

The six-month CMS moratoria restricting Medicare enrollment for hospice and home health providers are scheduled to expire Nov. 13, but the agency has not said whether it will extend them. The restrictions have disrupted some providers’ plans to open locations, expand through acquisitions or change ownership, leaving the industry to plan for an unresolved federal decision.

The national moratoria bar applications for new Medicare enrollment by hospice and home health providers and apply to certain changes in majority ownership. CMS stipulated that it would provide at least 60 days’ notice before the moratoria expire. According to the source report, the agency had not provided information on an extension as the deadline approached.

Providers told Home Health Care News that the restrictions have changed or stalled growth plans. Dean Alverson, president and CEO of LifeCare Home Health Family, said the moratorium affected the organization’s expansion plans, including its strategy of opening new locations in underserved and high-demand markets. He said that approach would no longer be available under the restrictions and could limit the organization’s ability to respond to patient needs and access gaps.

Rachel Hold-Weiss, a healthcare partner at Benesch Law, told Hospice News that some hospice clients had paused plans for new practice locations and acquisitions. She also described smaller operators who had hoped to sell as being unable to proceed. Hold-Weiss said Medicare Administrative Contractors had denied some enrollment applications filed before the moratoria began, disregarding their submission dates. The report does not provide figures for how many applications or transactions have been affected.

At a glance
updateWhen: Moratoria scheduled to expire Nov. 13,…
The developmentCMS’s temporary Medicare enrollment moratoria for hospice and home health providers are approaching their scheduled Nov. 13 expiration, with no public decision yet on an extension.

Expansion Plans Await CMS Decision

The decision matters because the restrictions affect how providers can grow, not only whether a particular application moves forward. New locations, ownership changes and acquisitions can shape where Medicare beneficiaries have access to hospice and home health services. Alverson said his organization’s de novo strategy had been used to expand access in underserved and high-demand markets; he argued the moratorium could limit that work and leave existing access shortfalls harder to address.

The uncertainty also affects operators trying to plan business transactions. Lanchi Bombalier, a partner in the healthcare practice at Arnall Golden Gregory, said providers that were committed to deals but had not reached their filing deadlines faced delays. She described the uncertainty as chilling industry activity. These are assessments from industry representatives, rather than CMS findings about the moratoria’s effects.

If the restrictions end on schedule, providers may try to restart plans that were put on hold, potentially creating a queue of applications and deals. If CMS extends them, some growth plans could remain delayed. Either course has consequences for providers, sellers and communities that depend on local services, although the report does not quantify the effect on patient access.

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Restrictions Reshaped Provider Growth

The restrictions are temporary, national measures covering hospice and home health enrollment in Medicare. Their scope includes applications for new enrollment and certain majority-ownership changes, so providers have faced limits on both opening new operations and pursuing some transactions. The stated expiration date is Nov. 13, and CMS said it would give at least 60 days’ notice before expiration.

Industry responses have included calls for CMS to use more targeted restrictions in areas where fraud has been prevalent, rather than applying a national measure, according to the report. That is a proposal from stakeholders, not an announced CMS policy. Bombalier also said states may impose their own moratoria or other restrictions, which could affect providers’ plans even if the federal measures end.

Hold-Weiss said that the effect has extended beyond expansion: some smaller hospice operators hoping to sell have been unable to move forward. She also reported denials of applications submitted before the moratoria started. The source report does not include CMS’s explanation of those decisions or the agency’s response to the industry concerns.

““The moratorium will impact our organization’s plans for growth and may affect broader operations.””

— Dean Alverson, president and CEO of LifeCare Home Health Family

Extension and Market Effects Unknown

The central unknown is whether CMS will let the moratoria expire on Nov. 13 or extend them. The report says the agency had not announced a decision. Although CMS stipulated it would provide at least 60 days’ notice before expiration, the source does not say whether that notice period had begun, what form an announcement might take, or whether CMS would alter the restrictions rather than extend or end them.

The scale of the disruption is also unclear. The report offers provider and legal-sector accounts but no count of blocked applications, delayed transactions, affected businesses or communities. It does not establish how many pre-moratorium applications were denied or give CMS’s account of the Medicare Administrative Contractors’ decisions. The extent to which state-level measures may add further constraints is likewise not specified.

Predictions about what follows are conditional. Hold-Weiss said an extension could prolong slower hospice growth, while an expiration could lead providers to resume delayed plans and create a bottleneck. Bombalier said the market could take time to regain its footing and that state considerations may keep growth at a lower rate. Those are industry assessments, not confirmed outcomes.

Watch for CMS Notice and State Rules

The next milestone is a CMS announcement on whether the restrictions will expire, continue or change. Providers and prospective buyers will need to assess that decision against application and ownership rules before restarting plans. The source report does not identify a scheduled CMS briefing, publication date or specific mechanism for the agency’s decision.

Providers may also monitor state actions, since Bombalier said state governments could establish their own moratoria or other restrictions. Even if the federal measures end, that could leave some businesses facing separate rules. If CMS allows the moratoria to expire, delayed expansion and transaction plans may resume, but industry representatives expect it could take time for providers to determine their next steps.

Until CMS clarifies its position, the practical outlook remains unsettled for providers whose plans depend on Medicare enrollment or covered ownership changes. The available reporting does not establish whether pending applications will receive different treatment after expiration, how quickly decisions would be processed, or whether CMS will adopt a more targeted approach.

Key Questions

What do the CMS moratoria restrict?

They restrict new Medicare enrollment applications for hospice and home health providers and apply to certain changes in majority ownership, according to the source report.

When are the moratoria scheduled to expire?

The six-month moratoria are scheduled to expire Nov. 13, 2026. CMS had not said whether it would extend them in the report.

How have providers said the restrictions affect them?

Providers and industry advisers told the publications that the moratoria have delayed plans for new locations, acquisitions and ownership transactions. These accounts are attributed to those sources; the report does not quantify the total effect.

Could the restrictions continue after Nov. 13?

Yes. CMS could extend them, but the source report says the agency had not announced a decision. CMS stipulated it would provide at least 60 days’ notice before the scheduled expiration.

Could state rules affect providers if the federal moratoria expire?

Potentially. Bombalier said states may establish their own moratoria or other restrictions, but the report does not identify specific state actions or rules.

Source: rss

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